1. Requirements for Key Facts Statement for Open Finance-related service offered by TPPs

1.1 Content Requirements:

The Key Facts Statement (KFS) for Open Finance-related services provided by Third-Party Providers (TPPs) must adhere to specific content requirements to ensure clarity and transparency. Below are the essential elements that should be included in the KFS, as guided by the Central Bank of the UAE (CBUAE):

• Scope of Services: Clearly outline Open Finance-related services and API usage. Separate KFS documents should be developed for other financial products, such as lending and deposits.

• Service Description: Provide an accurate, clear, and legible description of the services, including terms, fees, obligations, limitations, and key requirements.

• Risk Warnings: Use "Warning" boxes to emphasize key risks, such as performance assumptions, potential monetary losses, or limited profit scenarios.

• Fee Disclosure: Disclose all applicable fees, including third-party and recurring charges. Specify how fees are calculated, their recurrence frequency, and duration.

• Terms Modification: Indicate whether the financial institution reserves the right to modify terms and state the notification period for such changes.

1.2 Format Requirements:

The Key Facts Statement (KFS) must be a stand-alone document, distinct and separate from other materials. It should be concise, ideally limited to two pages, and written in plain, easy-to-understand language to ensure clarity and accessibility for all users.

1.3 Process Requirements:

The Key Facts Statement (KFS) must be provided early in the sales process, being the first document presented to the consumer. The consumer must acknowledge receipt of the KFS by signing it before signing the contract. Additionally, the KFS should be made available to consumers upon request.

Continuous disclosure is required, meaning the KFS must be provided at every relevant stage, including before offering the product, during the sale, and throughout the contract term.

2. Suggested Template for Key Facts Statement for Open Finance related services

2.1 Service Overview

a. Data Sharing

Data sharing involves defining clear policies and practices to protect customer information. Key considerations include:

• Data Types: Specify the types of data to be shared (e.g., personal information, financial history, account details).

• Purpose: Clearly state the purpose of data sharing, such as providing budgeting tools or personalized financial products.

• Consent management: Explain how customers can manage or revoke access to their data through consent management systems.

• Data storage location: Specify the location of the data stored

• Data retention: Indicate where data is stored and clarify whether the TPP retains data after service termination, including retention duration.

b. Payments

Payment initiation services should be transparent, providing customers with a clear understanding of the process. Key elements include:

• Payment Initiation: Describe how payments are initiated for different types of payments

• Variable Recurring Payments: Explain VRP functionality, including predefined triggers, customer controls, and payment limits

• Payment limits: Specify payment limits for various transaction types to ensure transparency.

• Payment execution: Describe the payment execution process, including processing times.

• Consent management: Provide instructions for managing or revoking payment initiation access through consent management.

• Notification Process: Detail notification procedures for payments, specifying when and how notifications (e.g., SMS, in-app) will be sent, including notice periods before VRP payments.

2.2 Fee Structure

The fee structure should promote transparency, enabling customers to make informed decisions. Key components include:

• Fee Structure: Detail all fees associated with data sharing and payment initiation, including third-party fees. Explain how fees are calculated and specify the frequency of recurring fees, if applicable.

• Example Calculation: Provide a sample fee breakdown to clarify costs and help customers understand the fee application.

2.3 Security and Customer Protection

Clearly outline the security measures and customer protection responsibilities of Third-Party Providers (TPPs). Essential aspects include:

• TPP Accountability: Define TPP responsibilities for safeguarding customer data, handling payments, and providing support.

• Fraud Protection: Describe fraud protection measures, such as real-time transaction monitoring and two-factor authentication.

• Potential Risks: Highlight potential risks associated with services to ensure customers are fully informed.

• Dispute Management: Outline the dispute management process, including clear steps for addressing issues and ensuring accessibility.

2.4 Potential for Changes

To ensure transparency, any potential changes to terms or fees must be clearly communicated. Key points include:

• Modification of Terms: Specify whether the financial institution reserves the right to modify terms and conditions, including fees.

• Notification Period: Provide the notification period for changes, ensuring customers are informed in advance and have time to review and respond.

2.5 Contact Information

To provide customers with accessible support, ensure the following details are included:

• Accessible contact information: Provide a phone number and/or email address for inquiries or further information and ensure the contact methods are clearly visible and easy to access for assistance or clarification.