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This audio version covers: Non-Bank Power Play: Leveraging CDR Expansion to Access Niche Lending Products and Competitive Data

Non-Bank Power Play: Leveraging CDR Expansion to Access Niche Lending Products and Competitive Data

Section 1: The New Paradigm: CDR and the Rise of Open Finance

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1.2. The Broker’s Mandate: Aligning Data Access with the Best Interests Duty (BID)

The Australian Competition and Consumer Commission (ACCC) has explicitly supported the expansion, emphasizing the importance of harmonizing the non-bank lending rules with existing rules that apply to the banking sector.[4] In its submissions, the ACCC also highlighted the need to monitor the impact of the CDR expansion on *consumers experiencing vulnerability*.[4] This is particularly salient in the non-bank sector, which often services ‘non-conforming borrowers,’ such as those with non-traditional income sources or poor credit histories.[4, 5]

This focus on vulnerable consumers provides a crucial strategic compass for brokers. Non-bank lending serves segments that require specialized, flexible products but who are simultaneously at a higher risk due to their complex financial circumstances. By utilizing standardized CDR data, brokers facilitate competitive transparency, directly mitigating the risk of vulnerable consumers being subjected to opaque terms or unsustainable loan structures. In essence, the broker, equipped with comprehensive data access, becomes the frontline mechanism ensuring consumer protection by facilitating accurate, rapid comparison and robust advocacy.

1.3. Transition from Open Banking to Open Finance: Defining the Non-Bank Sector

The formal extension of the CDR operation to non-bank lenders in March 2025, alongside the establishment of the sector’s requirements and timetable, marks the transition to a full Open Finance environment.[1] This expansion addresses a growing market reality: non-bank institutions are now fundamental drivers of credit supply in Australia, particularly in niche segments.

While Fintech Australia supports the overall expansion of the CDR to non-bank lenders, the industry body had previously encouraged the government to ensure the existing Open Banking sector was operating optimally before tackling the added complexity of Open Finance.[6] Concerns were raised that the CDR framework was not yet sufficiently mature, particularly regarding the need to resolve issues to improve access to data for small businesses.[6] This lack of maturity, especially regarding business participation, meant that approximately 2 million small businesses remained unable to access Open Banking data through their accounting software.[6]

The initial stages of the non-bank rollout, therefore, are likely to face some integration and maturity challenges similar to those experienced in the early phases of Open Banking. Brokers must be keenly aware that while the legislation mandates data sharing, the functional quality and reliability of the data feeds from newly obligated data holders will be crucial to realizing the promised benefits of speed and accuracy. The necessity of resolving small business data access remains high, as achieving this goal will encourage more competition and innovation across financial services, resulting in enhanced business-to-business (b2b) Software as a Service (SaaS) innovation and productivity gains.[6]

Section 2: Non-Bank Lending: A Strategic Review of Niche Markets

2.1. The Opportunity in Non-Conforming, Self-Employed, and Commercial Finance

Non-bank lenders, defined as institutions that do not accept deposits, have successfully carved out significant market share by capitalizing on opportunities created by regulatory shifts and evolving customer needs.[5] Following the Global Financial Crisis (GFC), traditional banks faced tighter lending regulations, creating a void that non-bank lenders expertly filled with more flexible lending options.[5]

These institutions excel in servicing segments that traditional Authorised Deposit-taking Institutions (ADIs) often find too complex or risky to serve efficiently under mass-market compliance structures. Key target segments include self-employed borrowers, non-residents, and those with less-than-perfect credit histories—the quintessential ‘non-conforming borrowers’.[5] This focus has translated into material market penetration: non-bank lenders now account for approximately 11% of the residential home loan market as of 2024, and their share of the commercial real estate (CRE) debt market is estimated to be about 16%.[5] The growth is driven by fewer restrictions in lending criteria, allowing non-banks to approve loans more quickly and provide funding to borrowers who struggle to meet the stringent requirements of major banks.[5]

For brokers, these statistics underscore the necessity of comprehensive, comparative access to the non-bank sector. Brokers serve as the vital connection, matching these specialized, risk-adjusted products to the complex and bespoke needs of their clients.

2.2. The Data Gap: Current Friction Points in Sourcing and Assessing Non-Bank Products

Historically, the strength of a broker dealing in non-bank finance lay in proprietary knowledge and deep personal relationships with individual lenders. The sourcing and comparison of niche lending products has been characterised by opacity and a lack of standardisation. Comprehensive product data often resides within non-standardized lender portals or requires manual, high-touch engagement.

The process of assessing serviceability for complex non-conforming borrowers is notoriously resource-intensive. It demands extensive manual collection and review of physical or scanned documents—including payslips, bank statements, and tax returns—for lenders to accurately gauge risk.[7] This manual process introduces significant friction, slows processing times, and drives up operational costs for both the lender and the broker.[7] The CDR expansion promises to eliminate these “outdated document-based processes” by automating secure, data-driven verification.[7]

The introduction of the CDR, therefore, fundamentally accelerates the competitive shift in the non-bank brokering segment. The advantage moves decisively away from deep, bilateral, relationship-based broking toward efficient, data-driven comparison and verification. Since standardized product data becomes instantly comparable, the strategic focus shifts to how rapidly and accurately a broker can use standardized data streams to verify a complex applicant’s suitability, rewarding technological early adopters.

2.3. The Regulator’s View: Information Gaps and Vulnerability

The expansion of the CDR is also driven by the needs of financial stability regulators. The Council of Financial Regulators (CFR) and the Reserve Bank of Australia (RBA) have noted significant information gaps concerning Non-Bank Financial Intermediation (NBFI). In particular, there is limited data available on lending quality and exposure in the Commercial Real Estate (CRE) sector.[8] Many non-bank credit lenders, such as specific debt funds or Responsible Financial Corporations (RFCs) below certain size thresholds, do not currently report their holdings or CRE lending quality, limiting insights into the sector’s financial health.[8]

The mandated sharing of ‘required product data’ and ‘required consumer data’ under the CDR rules addresses this regulatory visibility gap directly.[9] This compulsory data disclosure improves competitive dynamics for brokers by making more products visible, but it also provides regulators with crucial, standardized data streams for financial stability monitoring.

Furthermore, the Australian government, through Treasury, acknowledged the risk of creating excessive regulatory burden on smaller entities. They have addressed this by introducing revisions to clarify the operation of a ‘de minimis’ threshold, which determines the mandatory CDR obligations for non-bank lenders.[2, 4] This strategic narrowing of compulsory data sharing aims to avoid unnecessary compliance costs for data holders in relation to niche and small target products.[2] However, this regulatory approach creates a unique competitive dynamic: Non-bank lenders falling below the mandatory threshold are permitted to participate in the CDR voluntarily.[1] For these highly specialised, smaller entities, voluntary participation offers a pathway to gain competitive visibility and market access through the broker channel, which handles the overwhelming majority of Australian loan originations.[10] Brokers should, therefore, strategically monitor and encourage their niche lending partners to voluntarily join the CDR framework.

Section 3: Competitive Intelligence: Leveraging Standardised Product Data

3.1. The Definition of ‘Required Product Data’ and its Strategic Utility

The cornerstone of market transparency under the CDR framework is the standardization of product data. Under the CDR Rules, Data Holders (Non-Bank Lenders) must disclose ‘required product data’ when requested, subject to specific exceptions.[9, 11] Importantly, this information must be provided in a machine-readable format—an API endpoint—and no fee can be charged for its disclosure.[11]

Required Product Data is designed to encompass essential and comparable features of lending products, including interest rates, specific fees, detailed eligibility criteria, and general terms and conditions for specified loan types. The expansion of the CDR to the non-bank sector also incorporated provisions for ‘trial products.’ This ensures that while a product is being trialled, data relating to it may be excluded; however, once the product ceases to be a trial, the CDR rules apply, including retrospectively to data generated while the product was classified as a trial.[12]

This standardisation of product data, commencing on 13 July 2026 for all relevant non-bank lenders (Initial and Large Providers), represents a fundamental shift.[1] It means that comparison platforms will no longer rely on scraping websites or manual spreadsheet updates. Instead, they will ingest structured, verified product information directly from the source.

3.2. Driving True Comparison: How CDR Product Data Enables Faster, More Nuanced Product Matching

The use of standardized APIs allows Accredited Data Recipients (ADRs) to ingest and process non-bank product features instantaneously. This capability enables comparison platforms to execute real-time, algorithmic comparative analysis across potentially hundreds of specialized non-bank products.

This facilitates exceptionally precise matching, which is critical when dealing with complex client profiles. For example, a non-conforming borrower may require highly specific flexibility regarding Loan-to-Value Ratio (LVR), the exact purpose of the loan (e.g., specific commercial use cases), or historical credit event history. Standardized data allows brokers to filter instantly for the handful of products that meet those bespoke criteria, rather than manually cross-referencing eligibility documents.

The strategic outcome is profound: brokers shift their focus from the laborious task of manually searching for suitable products to the high-value activity of validating consumer suitability against specific product criteria that are provided reliably via standardized data feeds. This is anticipated to dramatically improve efficiency and decision accuracy for both residential and commercial niche lending.

3.3. Reducing Information Asymmetry: Identifying Competitive Edges in Complex Products

The overarching intention of the CDR expansion is to increase the availability of data, thereby stimulating financial technology innovation and empowering consumers (and their brokers) with a clearer understanding of competitive offerings.[2] Standardisation will bring unprecedented clarity to niche lending, particularly regarding pricing structures. It will become significantly easier to identify products that offer genuinely lower total costs or are better suited to a client’s specific long-term needs, thus forcing greater transparency and promoting genuine market competition.

The standardization of *product data*, effective July 2026, will create immediate and intense competition based on price and features within the non-bank sector. Currently, non-bank lenders can maintain competitive differentiation based on relationship exclusivity, bespoke underwriting decisions, or proprietary service models, which often obscures precise, comparative pricing. When APIs instantly deliver machine-readable pricing and features, price competition escalates, compelling non-bank lenders to distinguish themselves through superior speed, specialized service quality, or highly differentiated, bespoke underwriting criteria, rather than simply relying on information hiding. This enhanced competition allows brokers to instantaneously filter for the most cost-effective and appropriate solutions for their clients.

The regulatory framework has also addressed the common complexity of white-labelled products, aiming to clarify data holder obligations between the white labeller and the brand owner.[13] The intention is to ensure the entity most suitable for meeting data holder obligations provides the required data reliably, thereby preventing data silos and avoiding confusion for brokers utilizing comparison tools.[13] The successful management of these white-label data holder obligations requires technical vigilance from broker technology providers. White-label arrangements are ubiquitous in the Australian lending environment. If the technical implementation is flawed—for example, if the entity holding the contractual relationship with the consumer is different from the entity responsible for updating the product data—data integrity or timely updates could be compromised. Broker aggregators and technology platforms must ensure their data consumption architecture reliably handles these potentially distributed obligations to present accurate and consistent product information to the broker.

Section 4: The Core Mandate: Critical 2025-2027 Compliance Deadlines

This section details the critical, mandatory commencement dates for data sharing obligations, providing a clear timetable for the strategic preparation required by the broking industry. These dates govern when ‘relevant non-bank lenders’ must begin acting as Data Holders under the CDR Rules.[9]

4.1. Defining Obligation Categories: Relevant Non-Bank Lenders, Initial Providers, and Large Providers

CDR obligations commence progressively from 13 July 2026 for any entity classified as a ‘relevant non-bank lender’ that holds ‘required product data’ or ‘required consumer data’.[9] The precise commencement date depends on the provider’s size and classification:

• **Initial Providers:** These are generally smaller, non-ADI entities that fall below the threshold for classification as a Large Provider. They face earlier commencement deadlines for consumer data sharing.
• **Large Providers:** These entities meet specific size thresholds (typically based on total assets or volume) established in the CDR Rules.
• **Voluntary Providers:** Any relevant non-bank lender that falls below the mandatory thresholds (the ‘de minimis’ threshold) may choose to participate in the CDR voluntarily to gain competitive exposure.[1] If they choose to participate, they must comply with all relevant aspects of the CDR Rules.[1]

4.2. Regulatory Timetable: Compliance Deadlines

The regulatory rollout is strategically staged, ensuring that the necessary infrastructure for competitive transparency (Product Data) is established before the commencement of high-volume, sensitive Consumer Data access.

Table 4.1: Critical 2026-2027 Non-Bank CDR Data Sharing Commencement Dates

4.3. Staged Data Access: Differentiation between Product and Consumer Data Sharing Obligations

The strategic sequencing of the rollout is evident in the timeline. Product data sharing commences on 13 July 2026 for *all* relevant non-bank lenders.[1] This is followed by the first mandatory consumer data sharing deadline four months later, on 9 November 2026, applicable only to Initial Providers.[1]

This initial 4-month gap provides critical lead time for the industry. It allows technology providers, aggregators, and brokers to perfect the use of simpler, non-customer-specific APIs (Product Data) for robust comparison tools before having to manage the complexity and security requirements associated with sensitive consumer transaction data flows.[1]

A notable effect of this staged timetable is the inherent competitive advantage created for **Initial Providers** (smaller non-banks) in 2026. These providers must share consumer data six months earlier (November 2026) than the Large Providers (May 2027).[1] This crucial head start allows Initial Providers to be the first non-banks whose loan applications can benefit from the rapid, streamlined submission processes enabled by automated CDR consumer data. This early access to efficiency can enable these smaller, more agile non-banks to gain rapid market share against slower, larger competitors who must wait until the May 2027 deadline.

The rules also anticipate market evolution by providing a defined timeline for entities that become a Large Provider *after* 13 July 2025.[1] Such entities are given 12 months after attaining Large Provider status to comply with Product Data sharing and 15 months to comply with Consumer Data sharing.[1] This tiered approach suggests a proactive regulatory effort to manage potential market consolidation. By extending the compliance window, the CDR framework prevents regulatory barriers from immediately hindering rapid growth or mergers and acquisitions (M&A) activity within the non-bank sector, ensuring that data availability and competition continue even as the market structure changes.

Section 5: Intersecting Regulatory Shifts: 2025 Requirements Impacting Serviceability

While the CDR rollout for non-bank lenders is centered on 2026–2027, brokers must contextualize this future strategy within the immediate, material regulatory shifts affecting serviceability and compliance in 2025.

5.1. The Immediate Impact of BNPL Regulation (LCC contracts)

One of the most immediate and significant regulatory changes impacting client serviceability assessment is the commencement of Buy Now Pay Later (BNPL) regulation. From 10 June 2025, most BNPL services, now classified as Low-Cost Credit Contracts (LCCs), will be regulated under the same standards as traditional credit products.[14, 15]

The new regime, outlined in the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024 (Cth), mandates that BNPL providers comply with the National Credit Act and responsible lending obligations.[16] Practically, providers must hold an Australian Credit Licence (ACL) and become a member of the Australian Financial Complaints Authority (AFCA).[15, 16] The Australian Securities and Investments Commission (ASIC) released Regulatory Guide 281 (RG 281) to provide comprehensive guidance for these LCC providers.[15]

The simultaneous regulatory pushes—CDR transparency and BNPL responsible lending—underscore a coordinated governmental effort to normalize and institutionalize all forms of consumer credit data access. This regulatory environment is actively closing previous ‘gaps’ in debt reporting and liability assessment. This harmonization promotes a level playing field across credit providers and mandates that brokers, in their Best Interests Duty role, cannot afford to miss any form of debt, regardless of its source (bank, non-bank, or BNPL).

5.2. 2025 Compliance Snapshot

The CDR framework for non-bank lending was established in March 2025, shortly before the new BNPL rules took effect, requiring brokers to manage both the preparatory legal foundation and the immediate operational impact.

Table 5.1: Critical Regulatory Intersections for Brokers in 2025

5.3. Broker Due Diligence: Incorporating New Credit Liabilities Pre-CDR

The most acute operational challenge stemming from the 2025 BNPL regulation is the time lag before the supportive CDR automation arrives. The automated consumer transaction data from non-bank sources, which will include many BNPL providers, will not be mandatory until late 2026 (November for Initial Providers).[1] Brokers therefore face an immediate, approximately 18-month period (post-June 2025) of heightened manual scrutiny to verify these liabilities, ensuring compliance with the responsible lending obligations for LCCs.[14, 15]

This immediate operational challenge will dramatically increase the long-term broker demand for non-bank CDR data. BNPL usage is common, yet historically it has often been hidden or subject to time-consuming manual assessment. Post-June 2025, regulation forces brokers to factor LCC commitments rigorously into serviceability calculations. Because this manual process is arduous and inherently prone to human error, brokers will keenly anticipate the arrival of consumer data in late 2026, as it promises to instantly and reliably capture these LCC commitments, vastly reducing verification friction and improving decision accuracy. Broker technology solutions must, in the interim, ensure that current document collection and serviceability calculators are rigorously updated to account for BNPL liabilities and usage patterns, which can mimic revolving credit risk.

Section 6: Operational Readiness: Integrating Non-Bank Data into the Workflow

The competitive success derived from CDR expansion will not be determined by mere access to data, but by a broker’s capacity to translate that data access into demonstrable *utility*—specifically, faster processing, higher accuracy, and superior client matching.

6.1. The Role of Fintech Aggregators in Data Consumption

Fintech platforms serve as crucial Accredited Data Recipients (ADRs) and data intermediaries, translating raw CDR data into actionable insights and seamlessly integrating them within existing broker workflows. These platforms are the engine room for data consumption and utilization.

NextGen, Australia’s leading technology provider to the lending industry, processes approximately 98% of all broker-originated mortgages through its electronic lodgement and loan processing platform, ApplyOnline.[10] NextGen is already utilizing Open Banking data for its ‘Financial Passport’ service, which delivers tamper-proof financial data directly to lenders, improving loan decisioning accuracy and reducing reliance on supporting documents.[10, 17]

The expansion of the CDR to encompass non-bank data simplifies this integration challenge for fintech providers like NextGen and other API platforms such as Basiq.[18] These platforms are designed to incorporate new data holder sources efficiently. By plugging in the newly mandated non-bank data streams, they will provide comprehensive financial insights across the entire lending market spectrum—traditional banking, non-bank residential, and non-bank commercial segments—all within a single, unified broker workflow.

6.2. Automated Income and Expense Verification for Niche Borrowers

Open Banking has already proven its value by enabling automated income verification for Pay-As-You-Go (PAYG) applicants, replacing the manual processes that historically slowed processing times and drove up operational costs.[7] The inclusion of non-bank consumer data, commencing in late 2026, is fundamentally transformative for brokers serving self-employed and commercial clients.

Non-conforming loans and commercial mortgages typically require extended manual underwriting due to complex, fluctuating income streams and specialised risk factors. By applying the proven principles of CDR data automation to non-bank transaction data, automated tools can analyze historical non-bank loan repayments, measure cash flow fluctuations across various business accounts, and verify expense management specific to complex personal or commercial structures. This capability enables faster, more confident credit decisions, particularly for lenders who specialise in these niche areas.[7, 19]

The brokers who effectively leverage these integrated platforms will achieve a significant speed advantage in processing traditionally complex, non-conforming applications post-2026. The ability to dramatically decrease the time from application submission to acceptance for niche loans fundamentally changes the economics and scalability of this market segment.

However, the realization of these operational benefits is highly contingent upon the quality of implementation by the data holders. Fintech Australia previously raised concerns regarding the quality of data and cumbersome user experiences during the initial Open Banking rollout.[6, 20] If non-bank lenders fail to implement robust, high-quality, and reliable APIs by the July 2026 deadline, the anticipated efficiency gains for brokers—speed, accuracy, and reduced verification friction—will not materialize fully. Therefore, continuous broker advocacy through industry associations and aggregators remains essential to push for robust implementation standards across the non-bank sector.

6.3. Cybersecurity, Consumer Consent, and Maintaining Trust

The integrity and long-term viability of the CDR scheme rely absolutely on secure, applicant-driven consent.[20] As brokers become Accredited Data Recipients (ADRs) or utilize ADR services, they must maintain the highest standards of cybersecurity and operational rigor. Staff require thorough training to clearly and transparently articulate the benefits, security measures, and the voluntary nature of data sharing to build and maintain consumer trust.[20]

In response to previous criticisms regarding the complexity and cost of execution in early Open Banking, the Assistant Treasurer announced a ‘CDR reset’ aimed at reducing costs, streamlining consent rules, and improving the experience for consumers and small businesses.[20] Brokers must ensure they are up-to-date on these evolving consent and operational rules to streamline their processes while remaining fully compliant. Fintech Australia emphasizes that the financial services sector, including brokers, must actively help customers understand the true value proposition of data sharing—access to tailored products, streamlined experiences, and improved financial well-being.[20]

Section 7: Strategic Compliance and Ethical Data Management

The acquisition of strategic power through CDR data access carries commensurate regulatory and ethical responsibility. Brokers must manage the ethical landscape of data use as carefully as the competitive landscape.

7.1. Addressing Data Concerns: Algorithmic Bias and Responsible Data Use

As automated data analysis and algorithm-driven decisioning become central to the lending process, the risk of algorithmic bias must be actively mitigated. The Digital Platform Regulators Group (DP-REG) highlights the significant risk that algorithms trained on existing, potentially biased content may perpetuate existing biases, marginalize certain communities, and negate a diversity of viewpoints.[21]

This risk is particularly pronounced when dealing with non-bank data, which inherently covers a population of ‘non-conforming’ or complex borrowers.[4] Brokers and their associated technology providers must ensure that the Artificial Intelligence (AI) and machine learning models used for automated assessment do not unfairly bias outcomes against these niche groups, promoting exclusion rather than inclusion. The DP-REG called for Australian lawmakers to ensure potential harms to individuals are mitigated and recommended enhanced transparency and user feedback mechanisms when deploying such tools.[21]

Furthermore, the CDR Rules impose strict prohibitions on the commercial exploitation of highly sensitive consumer data. The rules explicitly state that CDR data may not be used for the purposes of creating a profile for compiling insights on any other person identifiable by that CDR, and that CDR data may not be on-sold to other entities.[22] This legal restriction reinforces the scheme’s consumer-utility focus over commercial exploitation. Brokers must ensure their use of CDR data remains strictly confined to fulfilling the client’s immediate financial need and complying with the Best Interests Duty, rather than building proprietary marketing databases or internal risk profiles for non-CDR compliant activities. Any misuse risks severe regulatory penalties and a devastating erosion of the public trust established within the scheme.

7.2. The Increasing Risk of Re-identification

A more subtle, yet growing, risk relates to de-identified data. While identifiable CDR data is prohibited from being sold, de-identified CDR data *may* be sold. Crucially, when sophisticated actors combine de-identified CDR data with other large data sets, there is an increasing risk that the de-identified data may be able to be re-identified.[22]

As the CDR expands to include non-bank data, the sheer volume of niche and commercial financial data being accessed and transferred increases exponentially. Because non-bank data specifically relates to populations of non-conforming or complex borrowers, the potential for sophisticated third parties to re-identify and target these often vulnerable groups increases significantly.[22] This demands continuous regulatory oversight and heightened diligence in data handling protocols by all accredited participants.

7.3. Training and Education: Ensuring Staff Understand Consent Models and Data Utility

To manage these ethical and compliance obligations effectively, brokers must move beyond rudimentary compliance training. Staff need comprehensive education on the nuances of CDR consent, including consumers’ rights to withdrawal and the exact limits of permitted data uses, ensuring full transparency.[20] Adherence to accreditation standards for handling sensitive data is mandatory, and engagement with the ACCC and Treasury is encouraged via dedicated feedback channels.[1, 9] Brokers, leveraging their scale through aggregators and associations (such as the MFAA or FBAA), are uniquely positioned to provide practical feedback on data quality, especially for complex or bespoke commercial products, thereby helping to refine the framework iteratively.

Section 8: Strategic Recommendations for The Broker Times Audience

The expansion of the Consumer Data Right into non-bank lending is not an incremental update; it is a strategic repositioning of the entire specialist finance market. The competitive advantage will belong to the broker who can successfully operationalize the new data streams faster and more accurately than the competition.

8.1. Technology Adoption Roadmap: Preparing for the 2026 Data Streams

A phased, disciplined approach to technology adoption and platform integration is necessary to maximize the strategic utility of the CDR rollout:

Phase 1: Compliance and Platform Alignment (Q2 2025 – Q2 2026)

Phase 2: Strategic Data Activation (Q3 2026 – Q2 2027)

8.2. Competitive Differentiator: Mastering the Niche Data Ecosystem

The strategic imperative for the Australian broker is clear: the ability to master the aggregation and responsible use of non-bank CDR data will be the single greatest differentiator in the specialist finance market over the next three years.

By leveraging standardized, machine-readable data, brokers can transition from relying on proprietary relationships and manual processes to becoming advanced financial strategists and data interpreters. This transformation enables the broker to identify the most suitable, cost-effective, and compliant niche lending solutions faster than competitors relying on legacy methods, allowing them to capture market share from both slower major banks and less technologically prepared intermediaries.[23]