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ServiceBC Registry Team working on Legal Entities
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BA - Draft Paper version of RTR initial filing and RTR update form #23396

Open mstanton1 opened 1 month ago

mstanton1 commented 1 month ago

As per RAID ticket #436, BC Registries has decided that we will allow paper based submissions for filings in a case where a client identifies that online filing in the Registrar's Transparency Register will cause undue hardship.

Forms will be required for the initial RTR filing and RTR update form.

mstanton1 commented 1 month ago

Previously we mocked up forms with size of sections / layout etc. However, this was when we had no forms designer in place. Have messaged Maribeth who reached out to Digital Delivery for information on what is required (i.e. is it a draft or simply access to go through the filing to create the form in their own format).

Have been invited to the Sept 26th SBC meeting to discuss if they will complete these filings.

mstanton1 commented 1 month ago

Reached out to Dani directly as we haven't heard back from Digital Delivery on the current process for forms submission (note, initial inquiry info forms process was sent through Maribeth to Digital Delivery Sept 18th).

Apt766525 commented 1 month ago

@mstanton1 Have created a draft of the BTR filing. Kindly review and let me know if any changes to be done. https://drive.google.com/file/d/1e9ozpBRnL1IQ9eMQSG-2t5auYbh3B9iq/view?usp=drive_link

mstanton1 commented 1 month ago

@Apt766525 this is a great format. It's really convenient that the forms editor could copy and paste the text right from the mock-up. This form will be extremely complex, so I've taken a first review and added comments below - but suspect we may need to think through the key question below of whether we have one form for Add SI and one form for Change SI, or whether we have this form cover both scenarios.

  1. The forms process email notes to identify a form that is similar if possible. Can you look at some forms posted on the bc registries site to see if there are others that might be similar?
  2. Change vs new SI filing?
    • Is this form for a new SI filing and change SI filing or is the intention to have two separate forms. Let's discuss what we recommend and mock up accordingly. If the same form is used for new SI's and changing SI's we'd need clear instructions. With change you'd only need to specify what has changed, whereas with a new filing you'd need to include all SI's.
    • For change SI we also need the ability to cease / delete SI's
    • For new SI filing we'd want to be able to list multiple people so may need SI 1, SI 2 with all the sections?
  3. Instructions are required.
    • Current instructions state not to mail the form but don't say how it would be submitted. Perhaps the instructions identify that Significant Individual filings must be complete electronically unless you have proven electronic filing causes undue hardship. The instructions could note that approval for paper submission can be requested through the manager of business services and include an email address (to be confirmed with Megan).
    • It would be good to look at other sample instructions as well to see what else to include. For instance, if it's standard in other forms to specify which sections are required (e.g. complete sections A to F. If you have been unable to obtain all information in those sections complete section G to outline why you have been unable to obtain information and what steps have been taken.
  4. Include disclaimer
    • We are required to include the FOIPPA disclaimer that we recently added to the filing in this form as well.
  5. Completing party section seems to not hold any purpose. It's in the system so we can prepopulate the SI name, but in this case we can't prepopulate anything so I believe it can be removed
    • Jointly or in concert only requires one table. That could be under the control of shares, control of votes and control of majority of directors section
  6. Confirmation section
    • The review page of the filing includes confirmation text. I can't recall if this is already in TEST or needs to be build, but a review should be completed to determine what that confirmation section incldues, as we likely need to include a corresponding piece on the form
Apt766525 commented 1 month ago

@mstanton1 Have updated the PDF based on the above comments. Will further work on the separate change filing version of the form. https://drive.google.com/file/d/1e9ozpBRnL1IQ9eMQSG-2t5auYbh3B9iq/view?usp=drive_link