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Project management repo for the SBL project
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[Story] Easily tell when a filing season starts and ends #122

Open angelcardoz opened 8 months ago

angelcardoz commented 8 months ago

Epic

Epic issue includes overview, complete list of user stories, technical and content requirements, user testing task ideation, and current design mock-ups.

[Epic] Small business lending filing home https://github.com/cfpb/sbl-project/issues/14

User story

As a filer, I want to easily tell when a filing season starts and ends, so that I know when I can start filing and when the deadline is approaching.

Acceptance criteria

Given a system user is logged in, when they visit the small business lending filing home page, then the system displays if the filing period is open or closed and the due date for the respective activity year.

Technical tasks

Developers should create technical tasks and add links (below) prior to sprint planning.

Research task

Front end

Back end

natalia-fitzgerald commented 8 months ago

@angelcardoz Pulling out a conversation from the task analysis.

What are we going to say is the "deadline" for MVP? This is a little tricky for MVP. We could setup the MVP to be for a 2024 full year collection. That'd then make the filing due on 3/1/2025 assuming we're going to have a 2 month filing period. However, we wouldn't normally allow filing to start until the end of the collection period. For MVP, I think we have to though. Also, in the data model we've been prototyping, there's 3 date fields for a filing: start, end, and due. I think each should be represented on the screen, especially since the first real filing season might be for a partial year. If we went with the original plan, it would have looked like:

start: 10/01/2024 end: 12/31/2024 due: 03/01/2024

This is what HMDA includes in their platform for dates. Instead of a start date they indicate that the filing period is open (or closed). Screenshot 2024-02-07 at 4 25 45 PM

natalia-fitzgerald commented 8 months ago

@angelcardoz @dan-padgett I'd like to better understand the post-MVP landscape for this component/user story so that I can design something that is flexible enough to accommodate what comes next. When a user selects the current filing year this will show when the filing season starts and end. When a user selects a previous year will this show the same information but for that previous year?

Screenshot 2024-02-08 at 10 53 50 AM Screenshot 2024-02-08 at 10 53 33 AM

angelcardoz commented 8 months ago

@natalia-fitzgerald, and @dan-padgett, I updated the acceptance criteria. I think it makes more sense now.

angelcardoz commented 8 months ago

@natalia-fitzgerald and @dan-padgett, coordinated with Monica, Hans, and Alex, and we are all on board with using 2024 as our "activity year". We realize that for beta users will be allowed to start filing before the end of the collection period (12/31/2024), which is strange, but we are ok with that. In summary, here are the dates: Start Date: 1/1/2024 End Date: 12/31/2024 Due Date: 3/1/2025

natalia-fitzgerald commented 8 months ago

@angelcardoz Can you confirm the following:

angelcardoz commented 8 months ago

@natalia-fitzgerald

angelcardoz commented 8 months ago

@sthomas93 @natalia-fitzgerald @dan-padgett I'm proposing we change the acceptance criteria to the following, "Given a system user is logged in, when they visit the small business lending filing home page, then the system displays if the filing period is open or closed and the due date for the respective activity year. "

Currently, the acceptance criteria reads as follows, "Given a system user is logged in, when they visit the small business lending filing home page, then the system displays the filing period start date and filing period end date for the current filing season." What are your thoughts?

natalia-fitzgerald commented 8 months ago

@angelcardoz In HMDA they have a heading that says "The 2023 filing period is open". This heading text only works if a filing period is parallel with the calendar year. In the example of beta you mentioned that the filing period will be: July 1, 2024 - March 1, 2025. So we can't refer the the filing period the way that HMDA does, as the [calendar year] filing period. After beta will the filing period and the calendar year line up or will there always be an overlap between years in terms of the filing period? If the filing period will always bleed from one year to the next the heading will have to be more generic, something like "The current filing period is open."...and then perhaps the body text specifies the date range.

I saw "filing year" referenced in HMDA:

Screenshot 2024-02-12 at 2 30 47 PM

Also, HMDA allows a user to select a "filing period"....It looks like to me they are defining the filing period as the year that the lending data was created? They later refer to "data for 2023" for the example I'm showing below.

Screenshot 2024-02-12 at 2 36 19 PM

angelcardoz commented 8 months ago

@natalia-fitzgerald The overlap will only occur during beta. After beta we'll see the filing period and the calendar year will line up, the way it does for HMDA.

Based on the HMDA help form, "filing year" means the year you file. "For data collected in 2017 and reported in 2018, select 2018 [for the filing year]". Source: https://[hmdahelp.consumerfinance.gov](https://hmdahelp.consumerfinance.gov/)/

Here I see "filing period" to be our original definition, the dates when a user can file data for a certain activity year.

image

It's not straight forward, but I can interpret "The 2023 filing period is open" to mean "The filing period is open for activity year 2023".

natalia-fitzgerald commented 8 months ago

@angelcardoz @dan-padgett I would like to loop back around on this to make sure that we have nailed down language for the small business lending filing platform.

I see some confusing things on the HMDA filing home page that are still not clear to me:

I would like to clarify all of this in order to make sure that for users we are delivering on this user story of presenting when a filing season starts and ends so that it is easy to understand.

@billhimmelsbach @hkeeler

nongarak commented 8 months ago

See GHE ticket #674 for details on what the rule says about filing timelines. Spoiler alert: not much.

Kibrael commented 7 months ago

Filing period: The date range within which a financial institution can file data for a specific activity year. This should not be referred to as a year, it is a date range.(my opinion) Activity year: The year for which the financial institution collected the data. Filing year: Based on HMDA my understanding is that this is the year the financial institution is expected to file their data (so the year within which the filing period ends) -- these definitions are great.

Kibrael commented 7 months ago

@chynnakeys Can you weigh in on the language usage for filing periods outlined above?

If possible I'd like to have clear and consistent language across both platforms.

My recollection is that there is some history on the HMDA side that may have influence things.

hkeeler commented 7 months ago

I generally agree on @natalia-fitzgerald's proposed terms.

  • Filing period: The date range within which a financial institution can file data for a specific activity year. This should not be referred to as a year, it is a date range.(my opinion)

Agree with everything here. 👍

  • Activity year: The year for which the financial institution collected the data.

If we're trying to come up with one naming convention that works across both HMDA and SBL, this should probably be activity period too. HMDA has quarterly filings for large institutions, so you really need to know which activity period is associated with which filing period. In HMDA's docs, there doesn't seem to be a term for this, instead just referring to date ranges for the Action Taken Date field.

I think this also meaningful for SBL as well for the first filing period, where the activity period is likely to be less than a year long.

  • Filing year: Based on HMDA my understanding is that this is the year the financial institution is expected to file their data (so the year within which the filing period ends)

Can we just not use this term? Only use filing period?

Having these both be ranges does change the data structure for filings a bit (@jcadam14, @lchen-2101). As it stands now, I think we have something like start, end, and due dates. We'll probably want to switch that up to activity_start, activity_end, filing_start, filing_end. This decouples activity and filing from each other, allowing for a gap between the two, which it sounds like may be the case for SBL.

natalia-fitzgerald commented 7 months ago

@hkeeler This is super helpful. Your suggestion to use filing period and activity period definitely makes this easier to understand, and more flexible (and precise) than the previous construct. In the post-MVP landscape, would the label for the dropdown be "Select activity period" (and if HMDA were to adopt this would their dropdown label change from "Select filing period" to "Select activity period"? Would the date on the card (filing home) then show the activity period?

In terms of how Activity period would be visualized on the card would it be something like Q1 2024 or 2024-Q1 for HMDA and just 2024 for SBL? Or should SBL somehow show that it's for the full year (as opposed to a quarter)?

Are we still thinking we'll use the following dates for beta?

hkeeler commented 7 months ago

In the post-MVP landscape, would the label for the dropdown be "Select activity period"

I think that makes sense.

(and if HMDA were to adopt this would their dropdown label change from "Select filing period" to "Select activity period"?

I think so if our goal is to use the same terminology, but there's obviously HMDA history that'd need to be taken into consideration.

Would the date on the card (filing home) then show the activity period?

I feel like you need all of the date fields to be represented in some way. I think it could all be on card unless that's too crowded or confusing for whatever reason.

In terms of how Activity period would be visualized on the card would it be something like Q1 2024 or 2024-Q1 for HMDA and just 2024 for SBL? Or should SBL somehow show that it's for the full year (as opposed to a quarter)?

I don't want to go too far down the road of how HMDA does thing or may do them in the future. As for SBL, it's all data-driven. We can add whatever human-friendly label/description we want to go along with either period. I think a Q4 2025 type label could be useful to go along with an activity period. Maybe less so for a filing period.

Are we still thinking we'll use the following dates for beta?

  • Activity period: 1/1/2024 to 12/31/2024
  • Filing period: 8/1/2024 to 3/1/2025

I'm not sure about all that. It definitely feels weird having an activity period overlap with a filing period. Can we just not have a filing period in the UI for MVP?...at least until we're closer to production where the dates of thing will be more clear? Seems more important to tell users the activity period so they know what data they should upload.

audayshankar commented 7 months ago

I was requested to weigh in on this ticket. The current terminology HMDA uses: When a year is coupled with the term "filing period", it refers to the year in which data was collected. For this current ongoing filing season, the platform says "The 2023 filing period is open" and in the dropdown, users are required to select 2023 as the filing period in order to upload data that was collected between Jan 1, 2023 and Dec 31, 2023. I see some contradictory info in above comments, so wanted to clarify that.

image

Using the current filing season as an example: We use 2023 to refer to it except in the instance of saying "2024 Filing Season". For example, we may say "The 2024 filing season for data collected in 2023 is ongoing". Otherwise all references to what we are currently in, is referred to as 2023. We will use the terms "on-time filing period" to refer to the timeframe between Jan 1 - March 1 when annual files are considered timely. Same for the periods of time that quarterly submissions are considered timely.

After the on-time filing period ends for annual filing (after March 1), the words "The XXXX filing period is closed" is displayed for that given year of data:

image

Additionally, users don't see the the term "activity year" on the platform during the submission process EXCEPT for the fact that there is a field called activity year that they are required to report in their actual LAR file. The files that are being submitted right now will have "2023" in the activity year for that specific field.

Please let me know if anyone has any questions, and I'm happy to help!

dan-padgett commented 7 months ago

@audayshankar To clarify something from your comment: initially you distinguished "filing periods" from "filing seasons", where the period referred to the year the data was collected and the season referred to the dates the data could be submitted. Then you mentioned "on-time filing periods" and defined it in a similar way to "filing seasons". Does "period" end up referring to two different things?

natalia-fitzgerald commented 7 months ago

@audayshankar In HMDA, what does "filing period" mean when it is not coupled with a year? Does the definition stay consistent whether or not "filing period" is coupled with a year? If so, what is the HMDA definition of "filing period"?

--

In discussions (above), the SBL team generally agreed on the following definition of filing period:

Filing period: The date range within which a financial institution can file data for a specific activity year (filing period should not be listed as a year but rather as a date range).

audayshankar commented 7 months ago

@audayshankar To clarify something from your comment: initially you distinguished "filing periods" from "filing seasons", where the period referred to the year the data was collected and the season referred to the dates the data could be submitted. Then you mentioned "on-time filing periods" and defined it in a similar way to "filing seasons". Does "period" end up referring to two different things?

@dan-padgett The difference between filing period and filing season is that when we are referring to the current ongoing filing period, the platform refers to it as the 2023 filing period since we are collecting 2023 data. The current filing season would be referred to as 2024 Filing Season as in "2024 Filing Season for data collected in 2023" but that is less frequently used (mostly to avoid confusion).

My reference to "on-time filing period" was not with a year attached. I mentioned that to indicate that the language on the site changes to say "XXXX filing period is closed" after the deadline passes. This year, after March 1, 2024 passes, the language on the site will change to say the 2023 filing period is closed + the additional info in the banner I posted a screenshot of. We don't frequently use the language "on-time filing period" to refer to annual filing, it's more commonly used in reference to quarterly filing.

@audayshankar In HMDA, what does "filing period" mean when it is not coupled with a year? Does the definition stay consistent whether or not "filing period" is coupled with a year? If so, what is the HMDA definition of "filing period"?

--

In discussions (above), the SBL team generally agreed on the following definition of filing period:

Filing period: The date range within which a financial institution can file data for a specific activity year (filing period should not be listed as a year but rather as a date range).

@natalia-fitzgerald We use filing period for annual filing to refer to the Jan 1 - March 1 timeframe, when we are collecting timely submissions. As mentioned in my reply to Dan, after March 1 this year, the language will change to say the 2023 filing period is closed. Our docs use "resubmission window" or "data collection window" to refer to the rest of the duration that platform is available for late filing or resubmission for a given year.

Here's a link to our FAQ where we explain our data collection timelines for filers: https://ffiec.cfpb.gov/documentation/faq/data-collection-timelines

natalia-fitzgerald commented 7 months ago

Thank all for the feedback and context!

@angelcardoz I'm moving the wrapping up of this discussion over to our terminology issue so that we can determine what terminology we want to use for SBL. https://github.com/cfpb/sbl-project/issues/128. I will post here to close the loop once a decision is made on the terms we discussed as a part of this issue.