Determine which fields are required to enable submission

natalia-fitzgerald commented 1 week ago

Task

Determine which fields are required to be populated with either a value or "not applicable" in order to enable the submission of a filing.

Primary question

Which information is required in order to enable the submission of a filing.

The platform already blocks filers from advancing to sign and submit without having the following information populated in the system:

Required to register

LEI
- Name
- Headquarter's address

Required to reach upload file step

Type of financial institution

Required to reach sign and submit step

Name and business contact information
Voluntary reporter status

So, which of the following missing information will block a user from submitting their filing at sign and submit?

Federal prudential regulator?

This field will always show the Federal prudential regulator (pulled from NIC) or "Not applicable" (not present in NIC). Our system will not prevent a filer from submitting due to incomplete or inaccurate Federal prudential regulator information.
TIN?
This field will always show the TIN or will be blank. Could be blank if financial institution is not in NIC and filer did not provide TIN on the update your financial institution profile page before navigating the filing steps. If we decide to block this user from submitting, we should consider flagging this with a warning alert on the View financial institution profile page (non blocking) and then with an error alert at sign and submit (blocking). Our system can block a user with a blank TIN from submitting a filing.
RSSD ID?
This field will always show the RSSD ID number or "Not applicable." A filer is responsible for providing their RSSD ID if they have one, when our system is showing "Not applicable." Our system will not prevent a filer from submitting due to incomplete or inaccurate RSSD ID information.
Parent entity information?
This field will always show the specific parent entity information or "Not applicable." A filer is responsible for providing this information if applicable. But our system has no way of preventing a user from submitting their filing with incomplete or inaccurate parent entity information. Our system will not prevent a filer from submitting due to incomplete or inaccurate immediate or top-holding parent entity information.

So, the only field that will be need to block a user from filing at sign and submit is TIN. All other fields are already required prior to sign and submit OR always show either a value or "Not applicable".

Should users that can provide their TIN in our system (those without RSSD IDs) still have access to the pressure valve at sign and submit or should they make the update at the Update your financial institution profile page? How do we differentiate (to a user) a pressure valve versus a standard user supplied update?

Secondary questions

Which data can a user edit/provide within the platform?
- TIN (some filers)
- Type of financial institution (all filers)
- Voluntary reporter status (all filers)
- Point of contact information (all filers)
- Parent entity information (some filers)
Activity period information that a user can not flag or correct (via the "pressure valve")?
- LEI (still need to confirm activity period LEI or current LEI)
- Type of financial institution
- Point of contact information
- Voluntary reporter status
- How about those that directly provide their TIN because they have no RSSD ID?
- How about those that directly provide parent entity information?
Can we use "Not applicable" for missing information in any of the parent entity and top holder parent entity fields?

What the rule says

The regulation requires filers to provide certain identifying information with their submission.

Financial institution identifying information.

A financial institution shall provide each of the following with its submission.

(1) Its name. (2) Its headquarters address. (3) The name and business contact information of a person that the Bureau or other regulators may contact about the financial institution's submission. (4) Its Federal prudential regulator, if applicable. (5) Its Federal Taxpayer Identification Number (TIN). (6) Its Legal Entity Identifier (LEI). (7) Its Research, Statistics, Supervision, and Discount identification (RSSD ID) number, if applicable. (8) Parent entity information, if applicable, including: (i) The name of the immediate parent entity; (ii) The LEI of the immediate parent entity, if available; (iii) The RSSD ID number of the immediate parent entity, if available; (iv) The name of the top-holding parent entity; (v) The LEI of the top-holding parent entity, if available; and (vi) The RSSD ID number of the top-holding parent entity, if available. (9) The type of financial institution that it is, indicated by selecting the appropriate type or types of institution from the list provided. (10) Whether the financial institution is voluntarily reporting covered applications from small businesses.

Financial institution data points

Field name	User can edit in platform	User can note/flag changes to historical data (pressure valve)	Field contents	Data source	Notes	Field must contain value in order to file
Financial institution name	No	Yes	Populated	Always pulled from GLEIF		Yes
Headquarters address	No	Yes	Populated	Always pulled from GLEIF		Yes
Legal Entity Identifier (LEI)	No	No	Populated	Always pulled from GLEIF		Yes
Legal Entity Identifier Status	No	No	Issued or Lapsed	Always pulled from GLEIF		N/A
Research, Statistics, Supervision, Discount Identification (RSSD ID) number	No	Yes	Populated or "Not applicable"	Always pulled from NIC		No (can show "Not applicable")
Federal Taxpayer Identification Number (TIN)	Yes (conditional)	Yes	Populated or Blank	NIC or filer supplied (mainly non-depositories)	Supplied by filer if absent from NIC. Not all institutions are listed in NIC, so many (non-depositories) will need to provide.	Yes (cannot file if blank)
Federal prudential regulator	No	Yes	Populated or "Not applicable"	Always pulled from NIC		No (can show "Not applicable")
Type of Financial Institution	Yes (all filers)	No, because it can be directly edited in the platform	Populated or Blank	Filer		Yes (cannot file if blank)
Immediate Parent Entity Name	Yes (conditional)	Yes	Name or "Not applicable"	GLEIF, NIC, or filer supplied (conditional)	Supplied by filer if absent from NIC/GLEIF	No (can show "Not applicable")
Immediate Parent Entity LEI	Yes (conditional)	Yes	Populated or "Not applicable"	GLEIF or filer supplied (conditional)	Supplied by filer 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.	No (can show "Not applicable")
Immediate Parent Entity RSSD ID	Yes (conditional)	Yes	Populated or "Not applicable"	NIC or filer supplied (conditional)	Supplied by filer if FI is absent from NIC but FI's parent is in NIC	No (can show "Not applicable")
Top-holding Parent Entity Name	Yes (conditional)	Yes	Populated or "Not applicable"	GLEIF or filer supplied (conditional)	Some institutions will have top holders that are not listed in either NIC or GLEIF. Supplied by filer if absent from NIC/GLEIF.	No (can show "Not applicable")
Top-holding Parent Entity LEI	Yes (conditional)	Yes	Populated or "Not applicable"	GLEIF or filer supplied (conditional)	Supplied by filer 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	No (can show "Not applicable")
Top-holding Parent Entity RSSD ID	Yes (conditional)	Yes	Populated or "Not applicable"	NIC or filer supplied (conditional)	Supplied by filer if FI is absent from NIC but FI's top holder is in NIC	No (can show "Not applicable")

Filing specific data points

Field name	User can edit in platform	User can note/flag changes to historical data (pressure valve)	Field contents	Data source	Notes	Field must contain value in order to file
Voluntary reporter status	Yes (all filers)	No, because it can be directly edited in the platform	Voluntary reporter or Not a voluntary reporter	Filer		Yes
Point of contact	Yes (all filers)	No, because it can be directly edited in the filing flow	All required content is populated	Filer		Yes

natalia-fitzgerald commented 3 days ago

@nongarak Can you re-read through this ticket and let me know what you think? Where I landed is that all required financial institution information fields (the list of 10 from the reg) are required to have a value (either value or Not applicable) to move forward in the platform prior to reaching sign and submit. Only blank TIN is not blocked before sign and submit. So should we require it on sign and submit before a user can click submit filing?

nongarak commented 3 days ago

Just re-read. My take:

All FIs MUST have a TIN to file. There is no FI that will not have a TIN. I think it's an @angelcardoz question as to where we require that - either in the stages prior to S&S or at S&S. I don't think the data team has a preference (but correct me if I'm wrong @Kibrael).
re: the "pressure valve" for institutions who don't have NIC data or parent information in GLEIF - you raise a good point, how do we have them report 12/31 and filing date information at the same time, if we do that. I'm not sure what the solution there is.
re: "Can we use "Not applicable" for missing information in any of the parent entity and top holder parent entity fields?" - yes, I think Not Applicable is accurate. If it's applicable, they must provide it. If they aren't providing it it's because it's Not Applicable.

natalia-fitzgerald commented 3 days ago

@angelcardoz @nongarak

Ok so it sounds like we've all reached the same conclusion, that TIN is required to be provided before a filer can submit a filing.
- Do we need to confirm this with regs or can we design based on the interpretation that a filer must provide TIN in order to submit their filing?
In terms of whether we should block the user at sign and submit OR before they reach sign and submit, that's a UX question that we can explore once we confirm the data/reg question.
- In the current design (live on beta) a user could reach sign and submit with no TIN (blank field). In other words we are not currently blocking them before they reach sign and submit
re: the "pressure valve" for institutions who don't have NIC data or parent information in GLEIF - We aren't working on designs yet for activity period (from the sign and submit or financial institution profile perspective) but I will flag this to @dan-padgett as something we should work through as we build out the task analysis.

billhimmelsbach commented 3 days ago

I think we need to talk to regs, since preventing filing submission was a big sticking point last time. I'd probably couple this with the LEI status conversation generally when we go to regs with these questions, since they are related.

I personally wouldn't block them until the sign and submit page, since we don't have any validations that require a valid TIN. I'd be interested in showing them a warning earlier though.

natalia-fitzgerald commented 3 days ago

@billhimmelsbach I have design explorations where we show a warning alert (page level and field level) on the View and Update financial institution profile pages AND then the error alert (page level and field level) on the Sign and submit page.

In terms of coupling it with the LEI conversations when we discuss with Regs, my only concern would be that the LEI status questions may complicate this TIN piece which seems a lot more straight forward. LEI status is not a data field in the list of required financial institution identifying information from the reg and it's not historic/activity period data --- https://github.com/cfpb/sbl-ux/issues/2#issue-2573954515 and so I see it as different.

Might we want to ask about TIN and perhaps even share the early designs for the warning on View/Update and error on Sign and submit and free up this blocker first? And then we can tackle lapsed LEI?

This is a very preliminary design of how we could block a filer at sign and submit for missing TIN.

billhimmelsbach commented 3 days ago

Might we want to ask about TIN and perhaps even share the early designs for the warning on View/Update and error on Sign and submit and free up this blocker first? And then we can tackle lapsed LEI?

Sounds good to me. I'd be interested in how this is going to be presented to regs.

nongarak commented 3 days ago

Oop - I didn't see these latest posts before I hit send on my email to Regs. Feel free to respond to that email with additional details if you like! I asked for a response by COB Tuesday (which seemed reasonable to me).

cfpb / sbl-ux