Open Banking For Non-Bank Lenders - A Data Holder's Crib Sheet

So, with bank data (mostly) fully compliant and in a uniform schema or format for consumption by 'Open Banking', attention has turned to Non-Bank Lenders who are now required to get their proverbial data houses in order to comply with the Consumer Data Right (CDR) requirements.

First up is making your Product Reference Data (or PRD) available and after that your customer data.

Now this may sound fairly simple on paper, but the reality is a little more complex.

Many a bank perhaps underestimated the sheer scope of the task ahead of them and, as first cabs off the rank, this was perfectly understandable.

Non-bank lenders have the advantage of some foresight in terms of the task ahead so what lessons can be learned, what insights gleaned from the poor banks who had to fly blind into a maelstrom of compliance and regulation with very little in the way of trainer wheels or manuals?

1. Understand Your Obligations

The compliance requirements for Data Holders vary depending on products offered, size of your loan book, how many brands you operate etc. Mortgage Managers are included in the new rules, despite not actually being the loan funder so this needs to be considered.

2. Start Planning Your Project Because It Is Going To Be Lengthy

Based on the time needed by banks, the Non-Bank Lender Deadline of September 2026 is going to roll around extremely quickly.

NBLs we’ve spoken to are at wildly different ends of the readiness spectrum. Some projects are scoped and ready to go, whilst others haven’t even made it to the priority list yet. [Plot-twist: it will quickly rise to the top].

3. Stand On The Shoulders Of Data Holder Giants

Leverage the expertise of those who have done the heavy lifting before and know the intricacies of such a project, and also where the slippery banana skins lie.

You know the old phrase: “an easy trap for young players.” Lean on the old sages in this area.

4. Consider Life After Data Holder

After the rain comes the sunshine.

I met with a roundtable group of mutual banks to suggest they enjoy the bountiful harvest of Open Banking by becoming a Data Recipient (a consumer of the Open Banking Data instead of just pony-ing it up for others to enjoy).

They asked how long such a project might take.

I said six to eight weeks should be plenty (given they could fast-track their accreditation as an ADI (bank)).

Jaws dropped, mouths were agape.

Having spent the best part of two years grinding through the Gulag, they simply couldn’t believe that they could be up and running with all the sexy, Open Banking goodness in such a short time.

Some jumped at it, others are still processing the trauma.

But, as a Non-Bank Lender, I’d take a two year view and assume that in that period, you’ll have become an accredited Data Holder (or been heavily fined) but, importantly, screen-scraping as a method of bank data collection will have been phased out, so you WILL need a way of ingesting data and therefore will need to become an open Banking Data Recipient.

So start planning for this STAT.

And, you might as well consider a vendor who can do both for you, wouldn’t you say?

Wych is actively working with Non-Bank Lenders on major Data Holder projects - reach out for an assessment of how best to approach your project.