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BIS Midata Review - Consultation

February 2014

Executive Summary

The UK Cards Association supports BIS in encouraging innovation in the current account and card sector, which is central to consumers’ everyday living. In the collaborative environment BIS has sought to create under the midata programme, the current account and card sector is progressing well against the original midata objective of providing consumers access to their personal transaction data in flexible ways, and hosting tools to help consumers understand and use this data. This is true both in a national and a global context, with UK consumers benefiting from more transparency and flexibility over their accounts than is available in most markets worldwide.

The key issue for BIS to consider in whether to push for further homogeny or innovation in this sector is understanding the best and most likely uses of personal transaction data. In our view, banks and card companies, in collaboration with various third parties, are already allowing the two key uses for personal transaction data to be met - comparison between providers in a
dynamic sector, and managing own consumption and saving time. This is supported by consumer feedback to banks and card companies, and the consumer surveys run as part of the midata programme.

We therefore believe legislation in this area is unnecessary, and would be disproportionate, with greatest impact on smaller ‘niche’ firms. It is also unlikely to be flexible enough to adapt to ever-changing technology and consumer demand. Innovation in this sector is a distinguishing feature between banks and card companies, and diversity among consumer offerings is an indicator of a competitive and mature market that reflects divergent consumer needs.

We are committed to continuing to work with BIS to help consumers access and use data in ways which will most benefit them and will allow for the development of innovative business ideas. We welcome further discussion on how to take forward work with the midata lab to further understand this sector.

To view the full consultation, click on the link below.

On 30 June 2014, BIS published a report on the midata voluntary programme, which concluded that further statutory powers were not needed to ensure customers could have access to their personal data in banking. The report notes the provision by most credit card companies of online accounts, which allow customers to download pdf statements of data from between several months and 3 years previously. The review also cites our response and states that switching rates in the credit card sector are ‘quite high at 20%’.

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