Can data from closed accounts be shared?

The following explains how Frollo interacts with closed bank accounts. As a Mortgage Broker, understanding these limitations is important for managing client data and expectations.

Why Closed Accounts Are Generally Inaccessible via Open Banking

Generally Open Banking cannot be used to retrieve data from accounts that have been closed, however, we are aware of some Data Holders (such as CommBank) that do allow this for a period of time after the account has been closed.

• Active Accounts Only: The Open Banking APIs (connections) are designed to work only with accounts that are currently active, operational and maintained by the financial institutions.
• Access Termination Upon Closure: When a bank account is closed, the bank typically stops all data access through Open Banking channels for that specific account.

What Happens to Data After an Account is Closed?

• Historical Data Retention: Banks in Australia are usually required to keep historical account data internally for a number of years.
• No Open Banking Access to Historical Data: Importantly, Open Banking does not provide a way to access this historical data from closed accounts.
• Direct Requests to the Bank: To obtain records or statements from a closed account, your client will need to contact the bank directly to request these.

What You Can Advise Your Clients

• Contact the Bank Directly: If historical data from a closed account is needed, advise your client to contact the bank to request statements or transaction history.

What Happens When an Account Already Linked is Closed?

If a bank account that was actively connected using Frollo is subsequently closed by your client, access to refresh that account's data typically ceases after closure.

Please be aware that the exact behaviour regarding access to closed accounts can also depend on the specific policy of the bank involved, even while a client's consent may still be valid.

• If the Bank Does Not Allow Access: If the bank's policy restricts access to closed accounts, when our platform tries to refresh data, the closed account will likely be automatically removed from the client's connected accounts, and only the remaining active accounts will be updated.
• If the Bank Allows Access: If the bank's policy permits, when our platform attempts to refresh, some data may still update. Depending on the bank, you can expect to receive an account statement for the closed account with a "Closed" account status, and some high level product information about the account, but no transaction data.

Example excerpt:

Key Actions to Advise Your Clients On

• Download Important Data: Before closing an account, advise your client to download or export any crucial transaction history or statements they may need.

By understanding these points, you can effectively guide your clients to use Frollo and the implications of closing their bank accounts.