The application of the CDR has the potential to provide opportunities for greater financial inclusion if done with appropriate guide rails. However these benefits do not exist in a vacuum. They must be balanced with an understanding of the sector the CDR is about to be applied to and the very real potential for it to exacerbate existing consumer harms and introduce new harms, if not appropriately constrained and mitigated.
It is important to acknowledge that the non-banking sector serves different demographics, functions and purposes in the financial services sector. There are companies operating in this sector that have historically contributed to substantial consumer harm, and are not accountable to industry codes of any real value.
Applying the CDR to the non-banking sector should be done with these issues clearly in mind with risks appropriately mitigated.
