Almost four months after the introduction of comprehensive credit reporting in the Australian consumer credit market an important element in the self-regulatory structure of the regime has yet to be put in place.Industry has proposed that access to credit files containing comprehensive data will be based on a reciprocity rule and a data exchange standard, but these have not been finalised.In simple terms, the rule is that if credit providers supply comprehensive data to credit bureaus they will have access to files with comprehensive data. If they do not supply comprehensive data, they will only get access to the old negative data in credit files.The new comprehensive reporting scheme will allow credit reporting agencies to add the following information to credit files: the date a credit account was opened; the type of credit account opened; the date a credit account was closed; the current limit of each open credit account; and repayment performance history.Dun & Bradstreet started putting comprehensive data into its system last month and said it expected to see organisations start accessing the data by the end of the year.However, the Australian Retail Credit Association, the credit reporting industry body, is yet to finalise its principles of reciprocity and data exchange, a voluntary code that will govern the exchange of comprehensive data. This code is separate to the mandatory code of conduct registered early this year.D&B's director of consumer risk solutions, Steve Brown, said the standard was close to finalisation and most of the data standards were locked down.Brown said the general principles were agreed and the work still to be agreed was "minor" and "granular". He said the industry was proceeding with the implementation of comprehensive reporting on the basis of agreed general principles.A long-time participant in both legislative and industry activities in relation to credit reporting and now a principal consultant at Inflexion Point Consulting, Michael Hartman, said the government had ruled out mandating provision of comprehensive data and left it to industry to sort out the arrangements for data exchange.Hartman said: "Industry has the challenge that comes from the fact that there are competing commercial interests among industry members. It must navigate those interests to get a final set of rules and a means of oversight."Hartman said he understood that the work was progressing well. However, there was still more work to be done once the principles of reciprocity and data exchange were finalised."The Australian Competition and Consumer Commission will likely have to authorise at least some of the rules, and part of the application for authorisation would seem to require making a case as to what the public benefit of the rules would be," Hartman said."The ACCC authorisation process is expected to take a minimum of six months and probably more. The purpose the credit reporting system is to strike a balance between privacy protection and making it more practical to differentiate between those who are likely to be able to manage the credit they want and those who are not."