Tuesday, September 18, 2018

Where ‘Open Banking’ frameworks are being developed for the policy objectives of promoting competition and empowering consumers, these are worthwhile objectives, but they come with some key design issues and considerations, particularly in the ways that different open banking frameworks are implemented across various jurisdictions.

The treatment of liability for data breaches and unauthorized or defective payments is one such consideration. The IIF’s new paper Liability and Consumer Protection in Open Banking describes some of the sources of new risks for consumers in open banking ecosystems, how these can be mitigated, and key features of compensation and dispute resolution frameworks. We propose a series of recommendations as the basis for a formal framework to protect users of open banking systems.

This paper is the third in the IIF’s series on data sharing and open banking, following our previous papers on Safeguarding Customer Data in the Financial Sector and Reciprocity in Customer Data Sharing Frameworks, collectively highlighting the most prominent design issues as various forms of open banking frameworks are pursued across regions. 

IIF Authors

Brad Carr

Brad
Carr
Senior Director, Digital Finance Regulation and Policy
+1-202-857-3648
bcarr@iif.com

Pablo Urbiola

Pablo
Urbiola
Policy Advisor
+1 202 857-3657
purbiola@iif.com

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