Following a two-month consultation with stakeholders interested in Open Banking, on 3 February, the Implementation Trustee of the OBIE presented his proposed revised Agreed Timetable and Project Plan to the CMA. The proposals include:
- no new implementation items for the CMA9;
- the removal of several activities to improve focus. These include Account Comparison and Trustmark which the Implementation Trustee considers should not be standalone activities. By removing these activities (amongst others), the Trustee hopes to ensure that priority is on those activities which specifically address poor API performance, missing payments functionality and low user adoption;
- a significant extension of implementation periods to provide more time for the CMA9 to work through backlogs, fix outstanding performance issues and focus on operational resilience;
- no major implementations for delivery in H1 2020. The only two delivery items due in the first half of 2020 (A2(a)(i) Two Way Notification of Revocation (formerly P2) and A2(a)(iii) Reverse Payments (formerly P7)) are already in progress and are not significant implementation-wise;
- Reverse Payments is to remain a mandatory implementation requirement;
- Sweeping and Variable Recurring Payments (VRPs) are to be treated as separate items. The Implementation Trustee believes that Sweeping is a priority use case for the Open Banking remedy;
- clarifying the nature of the Root Cause Analysis and potential Evaluation; and
- refocusing the scope of the Benchmark (A5) activity, which has been renamed as “Improvement of API Performance”.
The Implementation Trustee is optimistic that Open Banking can deliver on the CMA’s objectives under the proposed revised plan and considers that the proposals will help tackle the existing issues of poor API performance, missing payments functionality and low customer adoption.
The CMA is now considering whether to approve the proposed changes. Any interested parties should make representations to the CMA by 26 February 2020.