The Australian Competition and Consumer Commission has issued a final determination authorising the rules for participants in the comprehensive credit reporting system.The ACCC acknowledged the concerns raised in some submissions that the rules were overly prescriptive. It also acknowledged the concerns of consumer groups about a lack of clarity on the recording of repayment history when a consumer is under financial hardship arrangements.However, it said the expected benefits of the scheme would outweigh any detriment.The participation rules, the Principles of Reciprocity and Data Exchange, were drawn up by the Australian Retail Credit Association and submitted to the ACCC in February. The main element of the PRDE is the reciprocity obligation, where signatories to the comprehensive scheme (which is voluntary) agree that only those credit providers supplying comprehensive data to credit reporting bureaus can have access to comprehensive data in return.Another important element of the PRDE is the consistency obligation, which says that credit providers must deal with bureaus on a consistent basis. What this means is that credit providers must contribute data to all bureaus with which they have relationships at the highest level and amount at which they deal with any bureau.A third key element is that signatories accept that sanctions apply for non-compliance.Under the comprehensive credit reporting changes introduced last year, as part of an overhaul of the Privacy Act, the range of data that credit providers can provide credit reporting bureaus has been expanded to cover such things as a borrower's repayment history.The ACCC said in a media release yesterday that ARCA was working with consumer groups to resolve issues around the reporting of financial hardship.The most contentious part of the PRDE is Clause 15, which requires that a subscriber credit provider engaging in comprehensive reporting supply the same level of data to all bureaus with which it has service agreements.Veda complained that the rule would "cause many credit providers either not to participate in CCR data sharing at all or limit themselves to relationships with one bureau."Veda said: "This is due to the costs to all credit providers of participation in the PRDE and, in particular, of the consistency provisions. Credit providers will restrict themselves to a relationship with one bureau or they will incur significant costs. Either way they face a competitive disadvantage."This will reduce CCR data exchange. The PRDE will lead to less rather than more data exchange and greater data fragmentation."The ACCC pointed out that other interested parties, including credit providers, submitted that the ongoing costs of meeting the consistency obligation would be relatively small and would be offset by cost savings and other benefits.The ACCC said: "The ACCC accepts these views and considers that each credit provider will make a commercial decision whether or not to provide data and consumer data from multiple credit bodies, based on their estimates of the associated costs and benefits."