Disclosures

API - V 2.5

Introduction

Financial Institutions (FIs) are required by law to disclose to customers aspects of their banking service that needs their knowledge and permission. The FI is also required to maintain a record of the customer’s response (whether they accept or decline the disclosure). Beyond regulation, it’s simply good business. Letting your customer have control over important aspects of their banking instills confidence and enhances their satisfaction.

An example of such a disclosure is the request for a customer’s acceptance of Terms or Conditions (ToC) when enrolling for Online Banking. Another would be signing up for electronic banking statements.

The Disclosures API is a set of basic services used to manage disclosure records of two types:

  • FI Disclosures: This API facilitates the Creation, Retrieval, Update, and Deletion of the disclosures (their nature, text, status, etc.).
  • User disclosure responses: This API facilitates the Creation, Retrieval, Update, and Deletion of customer responses to disclosures (whether they accepted or declined).

Value

The Disclosures API enables Customers to:

  • Remain informed about terms and conditions, legal requirements and other aspects of their banking experience.

It enables financial institutions to:

  • Gain the trust of their customers by making clear representation of ToC, etc. and complies with regulations.

It enables the developer to:

  • Manage all aspects of disclosure records through one service.

What is supported

While the technical documentation in the API specs section describes the endpoints (or ways to call the API with different parameters to execute different actions), the following provides a simplified list of use cases for disclosures.

Managing financial institution disclosures: Financial institution disclosure records contain the data elements necessary to present users with information (such as a terms and conditions document) and to request their response.

The Disclosures API provides the methods to manage these records, including:

  •  Create: Used to create new disclosure records. The name type, content, status, and other elements are created to prepare a disclosure for use in an application.
  • Read: Used to call up a disclosure record, most commonly when required in a workflow. The read method is invoked when a user is prompted to read and accept a disclosure.
  • Update: Used when any aspect of the disclosure record must be updated (e.g., when the language of one has changed).
  • Delete – Used to delete any disclosure records that are no longer needed.

Managing user disclosure responses: Maintaining the records of user responses to disclosures is both a legal requirement and a good business practice. For example, when a user accepts a disclosure to begin using online statements, your system needs that acceptance on record to ensure delivery to the customer or member, as requested. In the event of a dispute, you’ll need to produce the acceptance (or decline) record indicating the user’s response.

The Disclosures API provides the following methods to manage these records:

  • Create: Used to create new user response records. The response is linked to the financial institution’s disclosure, to ensure the affected account and the date and time of the response. The response itself is recorded to indicate whether the user accepted or declined. 
  • Read: Most commonly used when running a process related to a disclosure (e.g., if the user accepted a disclosure to receive online statements, then the process for creating online statements would need to check off  that response).
  • Update: Used to manage changes, such as the reversal of a previous answer to a disclosure. For example, a user might opt into receiving online statements and later decide to return to paper statements. The time and date of this change are also recorded through this method.
  • Delete: Used to delete any user disclosure response records that are no longer needed.

Additional Product Details

Schema of a Financial Institution Disclosure Record

INSTITUTION_DISCLOSURE
INSTITUTION_DISCLOSURE_ID(PK)
INSTITUTION_ID
INSTITUTION_DISCLOSURE_NAME
INST_DISCLOSURE_DATA
INST_DISCLOSURE_DATA_TYPE
INST_DISCLOSURE_STATUS
INSERT_DATETIME
INSERTED_BY
UPDATE_DATETIME
UPDATED_BY
UPDATE_USER_ID
INSERT_USER_ID

A set of initial Disclosure Types are already present in the API

Disclosure Name Description Notes
OLS Online Statement Disclosures - Global Supported statuses: NOT_ACCEPTED, ACCEPTED
ESIGN ESign Disclosures Supported statuses: NOT_ACCEPTED, ACCEPTED
OLS (with accountId in request) Online Statement Disclosures - Account Supported statuses: NOT_ACCEPTED, ACCEPTED
IB Online Banking Disclosures Supported statuses: NOT_ACCEPTED, ACCEPTED
Any other name New Disclosures Supported statuses: NOT_ACCEPTED, ACCEPTED, NOT_ENROLLED, ENROLLED

Schema of a User Disclosure Response Record

INSTITUTION_USER_DISCLOSURE
INSTITUTION_USER_DISCLOSURE_ID(PK)
INSTITUTION_ID
INSTITUTION_USER_ID
ACCOUNT_ID
INSTITUTION_DISCLOSURE_ID(FK)
INST_USER_DISCLSOURE_STATUS
INST_USER_DSCL_STATUS_UPD_DT
INSERT_DATETIME
INSERTED_BY
UPDATE_DATETIME
UPDATED_BY
UPDATE_USER_ID
INSERT_USER_ID
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