Understanding Account Aggregator Framework (AA) from the end consumer's perspective

Understanding Account Aggregator Framework (AA) from the end consumer's perspective

?By CA Abhishek R Sharma

Regulatory Compliance Professional

Bengaluru

?1.1 Introduction:

Mr Sampath, who was working as a manager in a factory and wanted to avail housing loan, had to run pillar to post to collect his financial documents including bank statements from his multiple banking partners to arrive at his financial position. For the last many years, Mr Sampath also had to approach all his banker's and mutual funds advisers to arrange for him his financial records to file his Income Tax return (ITR).

?Like Mr Sampath, we also face similar situations in our day to day lives, where we have to approach our multiple financial services providers viz., Banks, NBFCs, Stock Brokers, Agents etc. to consolidate our investments and loan position.

?This particular issue has been the pain point for many especially while accessing credit, making investments and having a consolidated status of financial relationship across the financial eco-system. However, with the advent of the Account Aggregator Framework (AA), there has been a sigh of relief for many of us. Now, there will be comprehensive data sharing mechanism among the financial service providers such as banks, NBFCs. This data sharing will be pure with your consent in order to facilitate easy availability of financial records (bank transactions etc.) which could be used to avail services such as credit etc.

?1.2. Do we need the Account Aggregator Framework in India?

The answer is Yes. Account Aggregator gives customers’ the potential to share data easily between different financial service providers, by consolidating data in one place and providing a single digital framework to share it in real-time. No more running around collecting documents to open accounts, file for taxes, get loans.

?AA framework is a safe, consent-based framework giving you control over your data and quicker access to financial services, which means Mr Sampath would no longer need to run door to door to his lenders to access his transaction data. Mr Sampath can easily use the AA infrastructure to access his details of the transaction using the consent mechanism, which is very safe and secure and transact with much-needed ease.

?1.3 As a customer what are the advantages to the AA framework?

As a customer you have the following advantage to access your financial records using the AA framework:

?1.??????User-controlled data sharing

2.??????Unified consent management

3.??????Frictionless means to move data

4.??????Real-time access to financial services

?1.4 As a customer what I should know about the AA framework?

As a customer you should also know that, under the account aggregator:

?1.??????AA acts as a conduit and does not process the user’s data.

2.??????AA is ‘data-blind’ as the data that flows through an AA is encrypted.

3.??????AA can’t store any user’s data preventing potential leakage and misuse.

?In today’s world, when Regulators across the globe are harping on data localization and data privacy as important deciding factors in handling customer data, Mr Sampath need not worry about using the AA framework. The AA is recognized by the Reserve Bank of India (RBI) and to operate as AA, it needs to meet certain data security standards stipulated by the regulator. Hence, the AA framework or mechanism is a safe and reliant mode of data sharing.

?1.5 How Account Aggregator Operate in India?

Account Aggregators are registered with the RBI (the Apex Bank in India) and they share customer data securely between Financial Information Providers (FIPs) and Financial Information User (FIUs).

?·??????Financial Information Providers (FIPs): organisations that hold your financial data — e.g banks, insurance companies, mutual funds, pension funds, etc.

?·??????Financial Information User (FIUs): organisations that consume financial data to provide consumer services — e.g. banks, lending agencies, insurance companies, personal wealth management companies, etc.

?An Account Aggregator will facilitate the process of consent. Account Aggregator will be used to transfer financial data from FIPs to FIUs. Mr Sampath can very well construe that the Account Aggregator is very much like a central data registry that helps share between two parties under consent without storing it.

?Source – MoF, GOI, India

?1.6 Do I get empowered as a Customer If I use the Account Aggregator framework?

The answer is Yes. the Account Aggregator (AA) network, a financial data-sharing system that could revolutionize investing and credit, giving millions of consumers greater access and control over their financial records and expanding the potential pool of customers for lenders and fintech companies. Account Aggregator empowers the individual with control over their financial data, which otherwise remains in silos.

?As per the Ministry of Finance, Government of India, the Account Aggregator framework is a first step towards bringing open banking in India and empowering millions of customers to digitally access and share their financial data across institutions securely and efficiently.

?It is not to be forgotten; the Government has taken up numerous steps to facilitate digital transactions under digital India initiatives. There are numerous examples of it such as UPI (a virtual payment address, bank to bank smooth transfer mechanism), extending the Central KYC (cKYC) for non-individuals etc. Account Aggregator is one of such concrete steps to ease out the exchange of financial information of customers among the financial service providers to facilitate credit and investment decisions.

?Source – MoF, GoI, India

?1.7 The Seven key takeaways from the Account Aggregator Framework:

Here are the top 7 takeaways Mr Sampath and we all as a customer should know about the Account Aggregator Framework. It could be a revolution in the banking and fintech space as it will enable smooth digital loan and investment possibilities especially moving from traditionally based credit evaluation to a Cash flow-based credit evaluation and loan disbursements.

?1) Is my data safe - Account Aggregators cannot see the data; they merely take it from one financial institution to another based on an individual's direction and consent. Contrary to the name, they cannot 'aggregate' your data. AAs are not like technology companies that aggregate your data and create detailed profiles of you.

?The data Account Aggregator share is encrypted by the sender and can be decrypted only by the recipient. The end to end encryption and use of technology like the ‘digital signature’ makes the process much more secure than sharing paper documents.

?2) Registering with an AA is fully voluntary for consumers.

?3) How do I register with an Account Aggregator - You can register with an Account Aggregator through their app or website. Account Aggregator will provide a handle (like username) that can be used during the consent process. Today, four apps are available for download (Finvu, OneMoney, CAMS Finserv, and NADL) with operational licenses to be Account Aggregator. Three more have received in-principle approval from RBI (PhonePe, Yodlee, and Perfios) and maybe launching apps soon.

?4) A customer can register with any Account Aggregator to access data from any bank on the network.

?5) Is Account Aggregator services chargeable - This will depend on the Account Aggregator. Some may be free because they are charging a service fee to financial institutions. Some may charge a small user fee.

?6) An Account Aggregator is a type of RBI regulated entity (with an NBFC-AA license) that helps an individual securely and digitally access and share information from one financial institution they have an account with to any other regulated financial institution in the Account Aggregator network. Data cannot be shared without the consent of the individual.

?7) The Account Aggregator framework was introduced to make sharing financial data easier, quicker and more secure. It is the RBI that issue the master direction for the Account Aggregator framework and later in the entire data flow infrastructure was designed keeping in mind customer centricity at its core.

?1.8 Conclusion:

So, do check out with the applications of the Account Aggregators and register yourself to access the large pool of consented, and controlled data-sharing platforms that could help you do the business or access credit with ease, comfort and in a timely manner.

?Remember that, it is not only easy of doing business but also easy to living.

?Thank you,

?By CA Abhishek R Sharma

Regulatory Compliance Professional

Email:?[email protected] ?

LinkedIn :?www.dhirubhai.net/in/ars2020

Blog:?https://abhiaca27.wordpress.com/

?Note – Views are personal and the article is prepared based on the regulatory developments, industrial updates and government notifications.

?Disclaimer – Any resemblance of name, place of any individual in the article is purely coincidental and not mean to be specifically addressed to any specific individual.