Account aggregation is set to be launched this autumn in the UK by a variety of financial service providers. Already popular in the US, Canada and Australia, it will provide users with an online one-stop-shop to view their internet accounts at banks, mortgage lenders, stockbrokers, fund managers, insurance providers, credit card companies, loyalty cards and other similar services on one screen at the same time.
It means users won't need to remember a variety of pin numbers and passwords to access their myriad of online financial services. Instead, they simply go online and enter one pin and password to gain access to all their accounts.
At one glance, people using an aggregator service will be able to see their net worth – both their assets and liabilities will be set out. Information will be as up to date as if they had gone into each service separately.
Users will be able to manage their resources and time more effectively. There will be better price transparency and, with some services, the ability to perform product comparisons, calculate savings and receive online applications.
US consumers have been using aggregation services for more than 18 months. In a country renowned for its litigation, we are not aware of any major cases involving account aggregation.
The case for the UK
A number of legal questions need to be answered before consumers here can take the plunge and give the go-ahead to one aggregator to hold all their financial information in one basket.
It seems this will not affect the customer, as they are unlikely to know access through the aggregator is unauthorised and, as a result, are unlikely to face prosecution. However, the aggregator may be guilty of hacking if it penetrates secured areas of the service provider's site without “consent”.
To avoid this, it should notify the service provider that it is about to screen-scrape and allow the service provider to have the capability to terminate the action if authorisation is withheld. This gives the aggregator implied consent of the service provider to enter the site.
We believe customers will be protected by the Unfair Contract Terms Act 1977 and the Unfair Terms in Consumer Contracts Regulations 1999. Personal liability will, in any event, be limited to £50 for disputed transactions, unless fraud or negligence is proved against the customer under the Banking Code (January 2001). Negligence will be difficult to prove because it is likely the aggregators will hold passwords and PINs more securely than customers. In the event of a substantial disputed transaction, the bulk of the liability is therefore more likely to fall on the aggregator and its agency principal – for example, the bank or internet portal.
In any case, an aggregator could easily locate outside the jurisdiction of the FSA. However, if any financial advice is given on the back of an aggregation service, this could only be given if the individual is authorised.
If there is a security failure and money is lost, data corrupted or private information disclosed, ask who would be responsible for putting things right and compensating for loss. It is best to check with the aggregator and service provider sites.
At the end of the day, it is likely the aggregator will be a customer's first port of call in relation to any disputed transaction and, as such, a customer must ensure their aggregator has adequate security or insurance in the case of any losses.
Future will be aggregated
Account aggregation may well change the way we use our online services – it will speed them up and make them more efficient. Those who do not agree to be aggregated could soon find themselves losing business.
Customers will soon be faced with a variety of aggregators, ranging from major high street banks, independent financial advisers (IFAs), accountants and, on the technology side, internet service providers, portals, search engines and dedicated software providers who simply provide this service alone. It will be up to the customers to choose the most appropriate aggregation service.