[Epic] View or update your financial institution profile

[kristenshaw4]

Overview

• Each financial institution/LEI will have a financial institution profile that contains the data we have on file for that financial institution. https://github.com/cfpb/sbl-project/issues/11

Resources

• [Financial Institution Identifying Information (FI3) Key Points Documentation]

Pages

• View financial institution profile
  • Read-only
• Update your financial institution profile form
  • User can request changes to user supplied fields (RSSD ID, Type of financial institution, Parent and Top holder information)
  • Any changes to non-user supplied data should be handled at the source (GLEIF, NIC, etc.)
  • To request an update a user will fill out and submit a form to our support staff for processing.
  • Form is hosted on Small business lending platform and output is delivered to the case management system (email to case) https://github.com/cfpb/sbl-project/issues/82#issuecomment-1946983564

Tasks

• [x] Pull together initial list of relevant user stories for this epic
• [x] Make a list of the content requirements for this epic
• [x] Make a list of the technical requirements for this epic
• [x] Post current wireframes and mock-ups
• [x] Review wireframes and mock-ups with FEWD, BEWD, Data, SBL Help, Content team members
• [ ] Refine user stories to prepare for development phase
• [ ] Identify and capture tasks for user testing
• [ ] Conduct user testing

User stories

MVP (release date: 12/31/2024)

• [ ] https://github.com/cfpb/sbl-project/issues/267

Open beta (released 8/1/2024)

• [x] #37
• [x] #38
• [x] https://github.com/cfpb/sbl-project/issues/82
• [x] #37

Backlog

• [ ] #39
• [ ] Alert user if they don't have an active LEI, or if they are missing their TIN or Type of financial institution data they'll be blocked from submission.

Technical requirements

• Institutions API
  • Retrieve institution data by LEI and email domain

Content requirements

• Provide users with information about CFPB data sources for context and awareness
• Provide users with instructions for updating their FI's data
• FI data (see below)

Financial Institution data to show on this page (in this order):

• Financial institution name
• LEI (LEI is primary key, and name is recognizable to user)
• LEI status
• Headquarters address
• Email domain(s)
• Tax ID
• RSSD ID
• Federal prudential regulator
• Type of financial institution (SBL - MVP)
  • Financial Institution type (HMDA - future state)
• Affiliate
  • Parent Entity
    • Parent Entity Name
    • Parent Entity LEI
    • Parent Entity RSSD ID
  • Top Holder
    • Top Holder Name
    • Top Holder LEI
    • Top Holder RSSD ID
• Change History
(post-MVP)

User testing

Research Goals

• Learn what users expect to happen when they update the information for their financial institution.
• Assess how easily users are able to request various changes to their financial institution's information.
• Learn whether users expect to request changes to financial institution details other than the ones we currently allow.
• Understand what users expectations are around data that is pulled in from other sources (GLEIF, NIC).
• Identify any confusion around whether certain fields are applicable and how to obtain and format that information.

Task Ideation

• A user can find the financial institution details page
• A user is able to access the form to update financial institution details
• A user can request changes to identifying information and affiliate information
• A user understands how to change information that's pulled in from an external database

Current designs (MVP)

Updated: 2/16/2024

View	View (LEI inactive)

Update	Successful submission

Financial institution data points

Field name	User can edit in platform	User can note/flag changes to historical data	Possible field contents	Source	Note
Financial institution name	No	Yes	Populated or "Not available"	Always pulled from GLEIF
Headquarter's address	No	Yes	Populated or "Not available"	Always pulled from GLEIF
Legal Entity Identifier (LEI)	No	?	Populated or "Not available"?	Always pulled from GLEIF
Legal Entity Identifier Status	No	N/A	Issued or Lapsed	Always pulled from GLEIF
Research, Statistics, Supervision, Discount Identification (RSSD ID) number	No	Yes	Populated or "Not applicable"?	Always pulled from NIC
Federal Taxpayer Identification Number (TIN)	Yes (conditional)	Yes	Populated or "Not available"? (or would this one be blank?)	NIC or User supplied (mainly non-depositories)	Supplied by user if absent from NIC. Not all institutions are listed in NIC, so many (non-depositories) will need to provide.
Federal prudential regulator	No	Yes?	Populated or "Not available"	Always pulled from NIC
Type of Financial Institution	Yes (all filers)	No, because it can be directly edited in the platform	Populated or blank (or "Not available")	Platform (profile and sometimes in the filing flow (if not previously provided)
Parent Name	Yes (conditional)	Yes?	Name or "Not applicable"	GLEIF, NIC, or user supplied (conditional)	Supplied by user if absent from NIC/GLEIF
Parent LEI	Yes (conditional)	Yes?	Populated or "Not available"	GLEIF or user supplied (conditional)	Supplied by user if FI has a reporting exception in GLEIF that prevents the top holder from being linked but does in fact have a top holder with an LEI.
Parent RSSD ID	Yes (conditional)	Yes?	Populated or "Not available"	GLEIF or user supplied (conditional)	Supplied by user if FI is absent from NIC but FI's parent is in NIC
Top Holder Name	Yes (conditional)	Yes?	Populated or "Not applicable"	GLEIF or user supplied (conditional)	Some institutions will have top holders that are not listed in either NIC or GLEIF. Supplied by user if absent from NIC/GLEIF.
Top Holder LEI	Yes (conditional)	Yes?	Populated or "Not available"	GLEIF or user supplied (conditional)	Supplied by user if FI has a reporting exception in GLEIF that prevents the top holder from being linked but does in fact have a top holder with an LEI
Top Holder RSSD ID	Yes (conditional)	Yes?	Populated or "Not available"	GLEIF or user supplied (conditional)	Supplied by user if FI is absent from NIC but FI's top holder is in NIC

Filing specific data points

Field name	User can edit in platform	User can note/flag changes to historical data	Possible field contents	Source	Note
Voluntary reporter status	Yes (all filers)	No, because it can be directly edited in the platform	Voluntary reporter or Not a voluntary reporter	Platform (filing flow)
Point of contact	Yes (all filers)	No, because it can be directly edited in the filing flow	All required content is populated	Platform (filing flow)

[natalia-fitzgerald]

Notes from meeting on 8/18/2023

Here are the notes that @kristenshaw4 and I took during Friday's meeting with @Kibrael. Please feel free to edit to make these notes more accurate and useful.

• Spreadsheet shows how the information is mandated in the rule versus how we’re implementing it
• There is a column for user editable information
• RSSDn ID is another identifier that represents institution data in the NIC system(managed by the Fed)
• What fields can a user edit themselves?
• What is specific to HMDA versus what is specific to SBL?
  • LEI must be kept active and up to date for SBL. HMDA does not have this requirement (yet).
• We mostly know what is required for SBL. What we don't know is what method we have to force them to use to populate it. This would be like the HMDA Transmittal sheet.
• We may chose to only gather fields that won’t conflict with the data pulled in from our data sources
  • Basic entity information
• Contact is tied to an individual
• Or could there be multiple contacts?
• The point of contact may not be the person submitting the file?
• The contact may not have a user profile in our system
• Institution profile or transmittal sheet @hkeeler prefers that we have an institution profile and that the filing is a frozen in time version of the institution profile
• HMDA Transmittal sheet contains the institutions idea of their information
  • LEI, Tax ID, Institution Name, etc.
  • This can conflict with the entity data sources
  • David cares more about information related to the filing and not duplicative information with the entity data sources
• There is something called the HMDA panel versus the HMDA transmittal sheet.
• We can start with a very simple institution profile

Fields to include in R1 design

Please confirm that this list reflects the fields that should be included in the mock-up.

• Financial institution name
• HQ Address
• LEI
• Tax ID
• Business POC (Street address, State, ZIP, First and Last Name, Telephone number, Email address, FI email domain)

• Should there be a primary and a secondary email address?

  Tagging meeting attendees: @hkeeler @chynnakeys @lchen-2101 @kristenshaw4 @cdorney25 @meissadia @shindigira

[kristenshaw4]

• The View Financial Institution Details page will be READ-ONLY.
• If a filer needs to correct information, there will be information in the intro copy section that directs them to contact SBL Help; SBL Help will give further instruction and guidance based on the change that needs to be made
  • This avoids lengthy instructions for filers on how/where to make necessary updates

Financial Institution data to show on this page (in this order):

• FI Name + LEI (LEI is primary key, and name is recognizable to user)
• LEI Status
• Headquarters Address
• Email domain(s)
• Tax ID
• RSSD ID
• Federal Prudential Regulator
  • Type of Financial Institution (SBL - MVP)
  • • Financial Institution tye (HMDA - future state)
• Affiliate
  • Parent Entity
    • Parent Entity Name
    • Parent Entity LEI
    • Parent Entity RSSD ID
  • Top Holder
    • Top Holder Name
    • Top Holder LEI
    • Top Holder RSSD ID
• Change History


Type of financial institution:

A financial institution can select one or more of the following:

• Bank or savings association
• Minority depository institution
• Credit union
• Nondepository institution
• Community development financial institution (CDFI)
• Other nonprofit financial institution
• Farm Credit System institution
• Government lender
• Commercial finance company
• Equipment finance company
• Industrial loan company
• Online lender
• Other
  • (Use of “other” for type of financial institution. A financial institution reports type of financial institution as “other” where none of the enumerated types of financial institution appropriately describe the applicable type of financial institution, and the institution reports the type of financial institution via free-form text field. A financial institution that selects at least one type from the list is permitted, but not required, to also report “other” (with appropriate free-form text) if there is an additional aspect of its business that is not one of the enumerated types set out in comment 109(b)(9)-1.)

Decisions discussed:

• New pattern of the header navigation negates the need for a breadcrumb
• We will show neutral LEI status: Active or Inactive (not Deactivated)
  • HMDA filers can still file with an inactive LEI
  • SBL filers must have an active LEI
• We will show a visual alert/indication when an SBL filer has an inactive LEI status so that they can correct it with GLEIF; the message should be the same for SBL, HMDA, and SBL + HMDA because we won’t be able to differentiate filing status for some/most institutions
• Explainer microcopy should be included to address an Inactive LEI status so that a filer understands whether their FI is in compliance with the rule (icon + copy)
• For all institutions with an Inactive status:
  • MVP: Your LEI status must be active to file small business lending data. Visit add link here for details on how to reactivate your LEI.
  • Future state: Your LEI must be active to file small business lending data. An active LEI is not required to file HMDA data. 
Visit link for details on how to reactivate your LEI.
• We will provide an indication when a FI has incomplete information that needs to be provided before filing (ex. missing Parent RSSD ID)
  • Not available = CFPB has not been provided the necessary information
  • This user story is no longer needed because CFPB does not necessarily know when the data is not applicable for that institution

    As a filer, I would like to be alerted when I need to provide additional information related to SBL filing (ex. missing Parent RSSD ID)

  • Instead, we will provide a sentence of intro copy to explain that if there is data that CFPB does not have, but that the institution is required to provide, then they must provide it (Alex N. to write this copy)
• Do not need to create a separate profile page for Parent or Top Holder information / don’t need to link to these from FI details
• We do not need to show a visual indication that an institution’s data has changed (that user story is no longer needed/not a priority for MVP)
• Change history table could be a reusable pattern on the SBL Filing Overview (home) page
• Change history fields (Name, LEI, RSSD ID): For Parent and Top Holder, changes, adding a qualifier to the field name is enough, ex. "LEI" would refer to the financial institution LEI and the field would be "Parent entity LEI" and "Top holder LEI" for those specific fields under Field column.
• Mandatory fields for HMDA versus SBL: we have the updated table with all data fields and will show all relevant information for both SBL and HMDA on the future state landing page; will only show relevant SBL fields on the MVP version
• We do not need a glossary page for defining acronyms or terminology

Outstanding questions:

none

User stories

• As a filer, I would like to view my financial institution data as the CFPB understands it, so that I can make sure that my filing details will be accurate.
• As a filer, I would like to know where the CFPB obtained the data about my financial institution.
• As a filer, I would like clear instructions on how to change read-only financial institution fields, so that I can correct any errors prior to filing.
• As a filer, I would like to view the history of changes to my institution data
  • Who: person or automation w/ data source
  • What: Which fields changed from what to what
  • When: Timestamp
  • Why: automation or human note
• As a filer, I would like a visual indication that a change has been made to my institution data
• As a filer, I would like to review my Parent and Top Holder information to ensure it is accurate.
• As a filer, I would like to be alerted when I need to provide additional information related to SBL filing (ex. missing Parent RSSD ID)

[billhimmelsbach]

Heyo! Everything here looks good @kristenshaw4 and @natalia-fitzgerald, just one little change maybe in the user stories. I think we maybe need to cross out the last user story too after our discussions:

As a filer, I would like to be alerted when I need to provide additional information related to SBL filing (ex. missing Parent RSSD ID)

I think we settled on that we usually don't know what information they're missing based on the data we have, so we were going to avoid issuing alerts to the user?

[kristenshaw4]

@billhimmelsbach "Alerted" is probably the wrong word... I think we do want to visualize for them on this page that a field is missing what might be required information for them. Would that be a more accurate statement?

[billhimmelsbach]

This is a @Kibrael domain probably, but as I understand it @kristenshaw4, we won't know if most of these fields are required for the institution to include? I think "Parent RSSD ID" is particularly a weird one, since they are required to give it to us if they have one, but some won't since it's something that's assigned to them by the Federal Reserve Board based on their institution type. So it's possible a Parent wouldn't have an RSSD ID, as I understand?

Maybe something to chat about during the backlog meeting? It's a little sad to me that we can't do more frontend validation, but what's "required" seems pretty tricky.

[meissadia]

@billhimmelsbach I've done a review of these pages to try to identify any Design System React (DSR) components that are not yet implemented. The only one I've seen so far is TextIntroduction.

Are there any components you've identified as "missing" from the DSR that I can prioritize for development? Anything you've had to implement in your dev branch that needs to be ported over to the DSR?

Components I see ( √ = already in DSR)

Verified

• Headings √

Draft

• Banner √
• Divider √
• Link √
• Notification? (info) √
  • "Your LEI status must be active..."
  • Maybe just Icon w/ Text?
• PageFooter √
• PageHeader √
• PageNavigation √
• Pagination √
• Select (single) √
• Table √
• TextIntroduction
• Well √

[billhimmelsbach]

Thanks @meissadia for doing an inventory of them!

How do you want to handle the minor style differences between components in the DSR versus the final designs that are in Figma? Looking at the simplified table for instance:

DSR	Figma

So for example when I make the SimplifiedTable's top header row without a gray background color for the institution page, should it just be a one-off styling difference from the DSR's default style?

Maybe after this issue is completed, we can briefly chat about deciding between maybe rolling some of these similarly minor style changes into the DSR, adding a style prop for major ones, or just leaving them one-off changes?

[natalia-fitzgerald]

@billhimmelsbach I think we should talk through inconsistencies as they come up. Sometimes there may be DS variations that haven't been captured in the DSR. Or the Figma file could be a slight deviation from the component. Generally we'll want to default to a strict adherence to the CFPB Design System / CFPB Design System React (DSR) - unless there is a functional reason for deviating. For now let's discuss on a case by case basis as we work through building the page. The DSR is still a work in progress so we can't assume it's the source of truth yet.

There are a mix of components in the DSR. Some are "Verified" and some are "Draft". The table component has not yet been verified. I am adding the components that you will need for this page to the list I will prioritize for the verification review.

[natalia-fitzgerald]

@dan-padgett @angelcardoz I think it would be helpful for us to review the User stories and Technical requirements (blank right now) for this Epic. We should create a user story for the Salesforce form to be sure that we are capturing all of the details.

[natalia-fitzgerald]

Next steps

• [ ] @natalia-fitzgerald @dan-padgett will continue to work through the flow from the read-only in-app form to the case management system form to the submission confirmation
• [ ] @natalia-fitzgerald will then post updated mock-ups above
• [ ] The team will update the technical requirements accordingly

[natalia-fitzgerald]

@angelcardoz

Decision

Last week the team discussed the question of conditional logic for the "Update your financial institution profile" form. The team determined that the logic around when or what should be editable (for the identifying and affiliate sections) is too complicated for MVP.

For MVP:

• In the "Identifying information" section Federal Taxpayer Identification Number (TIN) and Research, Statistics, Supervision, Discount (RSSD) ID will be editable
• All fields in the "Affiliate" section will be editable.
• Mock-ups have been updated here: https://github.com/cfpb/sbl-project/issues/11#issue-1830007503
• In the mock-up the "Federal prudential regulator" is not editable because our understanding is that this always comes from our data (NIC through RSSD ID)

Post-MVP:

We created a task to capture this work which will be picked up post-MVP: https://github.com/cfpb/sbl-frontend/issues/248

These notes were pulled from the design comments and will inform the post-MVP task:

• If (and only if) RSSD ID AND LEI are empty (not in the database) then the name field should be available
• RSSD and LEI should never be editable for now
• IF we have an LEI or RSSD ID, then the name should be disabled (and hopefully populated), the LEI and RSSD data should also be disabled

@Kibrael @nongarak @billhimmelsbach