Affiliations and Company Passwords?

Entities
4

Thanks for the walkthrough of the scenario on Wednesday. I’m wondering if we can revisit the scenarios above to understand how the model applies to them?

(New) 5. From the meeting workflow in the 4th step the API Client would “Create a Business Registry API request for access to the Business(es)”.

  • On the first attempt let’s say the Law Firm sees the notification and approves the request to manage.
    - How does a vendor managing multiple Law Firm detect if that delegation is in place? Is there an API call to validate the delegation we can check before every Filing submission?

The real world scenario with no bad actors is as follows.

  • Firm A manages company 123 Inc. in Vendor
  • 123 Inc. moves representation to Firm B, who also uses Vendor
  • Firm A doesn’t close the 123 Inc. (data entry error) and files an Annual Report

Previously 123 Inc. would change their Company Password. In the delegation model, the API account has the delegation. Firm A could act in error and the Vendor has no mechanism to detect that.

(New) 6. From the February meeting it seemed that a new Incorporation through the API sets the affiliation to the Vendor account.
a. Does it also allow the vendor to programmatically add the Firm Account?
b. If not, is the expectation that the Firm has to seek delegation from the Vendor?
c. What specifies who has the responsibility to delegate? The vendor and Firm would never want the Vendor controlling the company data.

  1. Firms currently perform filings on behalf of their clients (BC Companies) in our product or through BC online interchangeably and do not require the Vendor to intervene to perform a BC Online filing.
    - I understand it’s designed to require intervention with the Delegation model. Unclear pending the answer to 6 if this model makes the Vendor the delegator in new incorporations.
  1. BC Companies change representing Firms as desired, sometimes with the new Firm using a different Vendor, and filings can continue without intervention from either Vendor using the Company Password.
    - I understand it’s designed to require intervention with the Delegation model. The new Firm and Vendor have to seek Delegation on N companies being transferred
    –
    (New) a. Does this scenario mean N requests for access could be sent by the Vendor at once?
    b. Does that mean the Firm has N email notifications to respond to?
  1. Firms expect to exclusively maintain and store their records and information (including KYC) about their Clients (BC Companies) pursuant to their solicitor-client relationship.
    - Unrelated to the Delegation issue so will split out as a separate ticket
  1. Firms require Vendors to segregate data as a best practice. Currently the vendor can track relationships around transactions as they define (including Firm or Office identifiers) but don’t perform the transaction itself (screen scraping method) so there’s no collating of all client data.
    a. Is the invoicing data and filing data returned by the registry coalesced for all Firms under a single Vendor API account if they all use the same Vendor?
    - Looks like this is by design but Vendors must track additional data provided in the API Reconciling PAD transactions - bcregistry

Thanks, H