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ServiceBC Registry Team working on Legal Entities
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UI Design: The individual is incapable of managing their own affairs. #18655

Closed steveburtch closed 3 months ago

steveburtch commented 10 months ago

Wireframes

https://www.figma.com/file/C2ThYIhZSO44dYBVGp8xAj/Register-Beneficial-Owners?type=design&node-id=3471%3A1489&mode=design&t=cMx5y2YtpTwtrzcN-1

Validation and Messaging Matrix

https://1drv.ms/x/s!AlejmOwhCCvlgcMDvsUyEofpuM1a9A?e=xJTG9F

Design Requirements

Bill 20

3 Section 119.2 is amended

(a) in subsection (2) by adding the following paragraphs:

(d.1) the individual's social insurance number, if any;

(d.2) the individual tax number, if any, assigned to the individual by the Canada Revenue Agency;

(f.1) if the private company ascertains, as a result of steps taken in accordance with subsection (3.1) or through any other means, that a determination that the individual is incapable of managing the individual's own affairs has been made, a statement setting this out; , and

(b) by adding the following subsection:

(3.1) If, at any time, a private company becomes aware that a significant individual may be incapable of managing the individual's own affairs, the company must take reasonable steps to ascertain whether, in respect of the individual, a determination that the individual is incapable of managing the individual's own affairs has been made by a court, health authority designate or prescribed person.


Section 399.52 indicates the registrar must omit from or obscure in publicly accessible information any info about an SI if the individual has been determined by a court, health authority designate or prescribed person to be incapable of managing the individual's own affairs.

The individual, the individual's personal or legal representative, or the private company in respect of which the individual is a significant individual must, on the request of the registrar, provide records, information or proof satisfactory to the registrar that the individual has been determined to be incapable of managing the individual's own affairs. I’m not sure if there has been any discussion around this topic regarding providing proof, but perhaps the LTSA has a policy about this that might help guide us.

mstanton1 commented 7 months ago

@steveburtch finance policy confirmed that the core requirement does not require an upload. However, it'd be ideal to have some sort of UX handling to advise users that they may be required to submit documentation to reduce those who incorrectly select that an SI is incapable of handling their own affairs.

I'd created #20102, but it doesn't look like this is built. Should we add the requirement for a warning into this ticket and have Julie review it (then close the one I created)?

steveburtch commented 7 months ago

@mstanton1 yes, we should add the warning. Who can supply the wording?

mstanton1 commented 6 months ago

Moving discussion items that were previously included as requirements in the body here for tracking. Note, most recently we received clear policy guidance that the core requirement does not require upload capability for documentation. It is preferred we collect documentation but can tackle that at a later time. At a minimum, it's suggested we include some sort of warning that documentation may be requested to reduce use of this feature in invalid cases.

Amanda

The registrar may request proof that the person is incapable of managing their own affairs. I will take this question back to registries to see if they want to proactively request proof or only request it when the enforcement officer becomes involved. They can still list them as a significant individual, but the information may have to be obscured/omitted from publicly accessible information.


Julie

There should be a box where the person filing can indicate Yes or No to the following question: “Has a determination of incapacity been made in respect of this individual?”

A court, health authority designate, or prescribed person can make this determination.

mstanton1 commented 6 months ago

@J-Baese there was a comment earlier asking who can supply the wording, but I also see a Yes / No question drafted in the comment above. Is anything needed here text wise?

mstanton1 commented 3 months ago

@J-Baese the Determination of Incapacity portion of the form was implemented with the updated warning. Can you confirm if there is further work to include a note that the person's information will be obscured, or whether the currently implemented version is sufficient?

Currently implemented (Dev screenshot):

image.png

Design Image from this ticket showing additional message:

image.png
mstanton1 commented 3 months ago

@J-Baese and @forgeuxGH5 have confirmed that the additional messaging advising of omission is displaying when the checkbox is selected.