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It is clearer than ever before that the CMA Order should be revoked, which would allow a transition to the Future Entity. Instead, as a direct result of the CMA Order still being in place, an Interim Entity is necessary to take forward non-Order work, so that Open Banking Limited (OBL) is limited to Order-only activity.
The pathway from OBL to the Interim Entity, and then to the Future Entity, is costly and complex, with no clear plan or timeline, and risks delay (as interim funding is sought) in the delivery of workstreams.
JROC needs therefore to play a lead role in simplifying and accelerating the pathway to the Future Entity, noting (as set out in the Future Entity Working Group Report) that the requirement for a Future Entity needs to be confirmed by the Department for Business & Trade given open finance, and all variants of smart data, falls under its remit. The focus should be on delivering a streamlined and cost-effective standards body designed to deliver today’s requirements. Any role for the Future Entity in other markets, whether they are financial services or beyond, should be postponed until such time as this has been achieved.
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