Update helper text to include RSSD ID update instructions

[natalia-fitzgerald]

Currently, the Small business lending data filing platform has an option to update several fields of user-defined data about a financial institution, including adding RSSD ID, and TIN. We are making a change to disallow user-supplied RSSD IDs.

Task

Update helper text on the View/Update your financial institution profile pages to include new instructions adding or updating a financial institution's RSSD ID through NIC

Current text

View

If your financial institution has an RSSD ID, and you wish to update the following information, visit the Federal Reserve Board. If your financial institution does not have an RSSD ID and you wish to make an update, submit a request to update your financial institution profile.

Update

If your financial institution has a Research, Statistics, Supervision, Discount Identification (RSSD ID) number, provide it here and we will pull your Federal Taxpayer Identification Number (TIN) and Federal prudential regulator from NIC. If not, provide your TIN.

RSSD ID update instructions (provided by data team)

If you have an RSSD ID and it's not reflected here, you have not properly linked your LEI to your RSSD in your FR Y-10 filings as required by the Federal Reserve Board. File an amended Y-10 or contact your reserve bank to link your LEI to your RSDD ID in NIC and we will populate that data in our system accordingly.

[natalia-fitzgerald]

@angelcardoz @nongarak @shindigira We are blocked on moving forward with this content task pending some NIC/Federal Reserve information that Alex is trying to confirm. If we do not receive word by Wednesday, 10/16/2024 we will come up with an interim solution based on the information we have and can then iterate at a later date when we confirm the information.

Questions

• Is FR Y-10 the required way to connect your NIC data with your LEI? How do independent banks connect their LEI to their NIC data?
• Should institutions in NIC always have their TIN? And why don’t they always have their TIN?
• Can we ask filers to update their TIN with NIC instead of us?

[nongarak]

Per the 10/10 email response from the Federal Reserve Board (the details of which can be found at [enterprise]/sbl-data-collection/issues/750#issuecomment-361742), the answer to this question:

• Is FR Y-10 the required way to connect your NIC data with your LEI? How do independent banks connect their LEI to their NIC data?

is that for many banks, the answer is yes. Banks that are regulated by the Federal Reserve, which includes banks that have a Bank Holding Company (BHC) as a parent and "state member banks" (which is just a particular kind of bank having to do with the way it is 'chartered', don't worry too much about it), are required to submit a FR-Y-10 form whenever they have a change in structure, including LEI updates. What we've learned from his email is that banks that are not regulated directly by the Federal Reserve (e.g. they have another prudential regulator, like the FDIC or OCC), are not obligated to file a FR-Y-10 and indeed follow a different process for updating information that gets populated in NIC. Rob was unable to tell me what the process is for those banks, except for that they update their information which may or may not mandatorily or not mandatorily include LEI directly with their regulators, and then those regulators send updates through some other process to the reserve banks, who then send it to the FRB to update NIC.

There are still lots of hazy pieces to this puzzle and early next week I will send a follow up email asking for clarification. Our contact and myself are both out tomorrow, so that's the earliest this could happen (unless @Kibrael or @cdorney25 want to take a stab at it).

[natalia-fitzgerald]

@nongarak Here are some options for accommodating the concepts shared above.

Full text with all of the information

This option is too long but includes all of the concepts

Shortened text options

Are we losing any essential context here or are the basics covered? I can move the linking of NIC to the Federal Reserve to the intro for the page because this seems to be something that applies to NIC as a whole and not just this section.	Option 1	Option 2

Page intro

This does make the intro text one line longer than preferred but it does seem like this qualifier needs to live closer to where we introduce the idea of NIC. Unless there's a specific reason we want/need it to appear in this immediate section of the page.	Current	Changed to accommodate Federal Reserve connection to NIC

[natalia-fitzgerald]

@angelcardoz I talked through this with @Kibrael and he has a preference for Option 1.

[nongarak]

Looks great! One thing: "If your financial institution has an RSSD ID number and "not applicable is shown below" - should the and be a but? Would that make it clearer? I think they're both logically correct, but I think but checks them and makes them consider that there may be an issue.

[natalia-fitzgerald]

Here's where we landed after today's dev/design sync.

• @angelcardoz

[natalia-fitzgerald]

@shindigira Here's where we've landed after some adjustments I made with Angel yesterday.

View your financial institution profile

Update your financial institution profile

• @angelcardoz @dan-padgett