All customer going through exempt flow, when enabling CIP exempt settings

API Support Customers
1

We enabled CIP exempt settings, after that all customer’s being on-boarded are going through exempt flow even if they do not fall under that category. A sample json used to onboard is as below

{
    "firstName": "Name first",
    "lastName": "Name second",
    "email": "temp@email.io",
    "type": "business",
    "address1": "18 12th Street Northwest",
    "city": "Washington",
    "state": "DC",
    "postalCode": "20009",
    "businessName": "Customer's businessName",
    "ein": "11-1111111",
    "controller": {
        "firstName": "Name first",
        "lastName": "Name second",
        "title": "CEO",
        "dateOfBirth": "1989-06-22",
        "ssn": "111-11-1111",
        "address": {
            "address1": "18 12th Street Northwest",
            "address2": "",
            "city": "Washington",
            "stateProvinceRegion": "DC",
            "country": "US",
            "postalCode": "20009"
        }
    },
    "businessType": "llc",
    "businessClassification": "fecd26f9-47ee-4af2-88e4-f37bdd584dd6"
}

Currently the settings for CIP exempt is turned off, but we want to enable it and support onboard of customer’s from both flows.
Even if businessClassification for the customer was not any of the accepted values in the doc provided, the customer went through the cip exempt flow.
We are pretty unclear at the moment what really caused our customer to go through cip exempt flow over regular flow.
What exact modification do we need to make to our requests to facilitate both cip exempt customers onboarding and normal cutomers onboarding.

2

Hi @Abhimanyu_Pandey, The way to trigger a UBO exempt flow for customer would be to use one of the following business Classifications.

The industry classification Id that corresponds to Customer’s business. Acceptable values include:
“Insurance - Auto and Home” - “9ed46ba3-7d6f-11e3-9efe-5404a6144203”
“Other Financial Investment Activities” - “9ed3cf71-7d6f-11e3-bf7b-5404a6144203”
“Commercial Banking” - “53ff176e-f832-4db3-89f4-d8f7044184c7”
“Credit Union” - “9ed3cf68-7d6f-11e3-8abb-5404a6144203”

Note: Selecting one of the above values is essential for triggering the exempt flow.

I see that the businessClassification value you’re using in the request body above is invalid. Would you be able to share an example customer who you did not use one of the above classifications for but they still went through the exempt flow?

3

yeah the businessClassification value above is invalid. It has random values. The actual value of businessClassification that was used was 9ed492a1-7d6f-11e3-9ccf-5404a6144203.
A sample payload with actual businessType and businessClassification used was:

{
    "firstName": "Name first",
    "lastName": "Name second",
    "email": "temp@email.io",
    "type": "business",
    "address1": "18 12th Street Northwest",
    "city": "Washington",
    "state": "DC",
    "postalCode": "20009",
    "businessName": "Customer's businessName",
    "ein": "11-1111111",
    "controller": {
        "firstName": "Name first",
        "lastName": "Name second",
        "title": "CEO",
        "dateOfBirth": "1989-06-22",
        "ssn": "111-11-1111",
        "address": {
            "address1": "18 12th Street Northwest",
            "address2": "",
            "city": "Washington",
            "stateProvinceRegion": "DC",
            "country": "US",
            "postalCode": "20009"
        }
    },
    "businessType": "corporation",
    "businessClassification": "9ed492a1-7d6f-11e3-9ccf-5404a6144203"
}

I have shared actual values that can be publicly exposed on the payload above. Basically the fields ‘type’, ‘businessType’, ‘businessClassification’ has the actual values used. Others are randoms. Hope it would be helpful. Please let me know if you need any additional information.

4

Hi @Abhimanyu_Pandey, thanks, this is helpful! Could you please also share a Customer Id as well? I can look up the data on our end to see what’s off.

5

Sure, the customerId was ad316921-8fd8-4420-8f2e-d5cfed211ab2.
Flow of events for this customer was

  1. Customer went through exempt flow and failed, customerId in this case was ad316921-8fd8-4420-8f2e-d5cfed211ab2
  2. We requested for disabling the exempt flow in our production.
  3. We disabled the initially submitted customer and resubmitted as new customer, new customerId 16877dea-8806-40ca-9cc6-4be0086ed5fa, this customer is in verified status.
6

Thanks for sharing the IDs @Abhimanyu_Pandey! I will share updates with you soon!

7

Thanks for looking into it.
Just following up for any updates.

1 Like
8

Hi @Abhimanyu_Pandey! Thank you for your patience! :folded_hands: Just wanted to share with you that we’ve determined and logged this on our end as a bug with the account setting that is used to mark customers as UBO exempt. Our dev team is actively investigating this issue. Although we might not be able to share a resolution today, I wanted to assure you that we’re looking into this with top priority.

1 Like
9

Hi @Abhimanyu_Pandey! Thank you so much for your patience as we looked into this. Your feedback was incredibly helpful.

Our team has completed the investigation, and we have an update for you. It turns out that the issue wasn’t with your account settings but was actually a matter of incomplete documentation on our end. We’ve discovered that there are additional businessClassification UUIDs that trigger the exempt flow, and the UUID you used, 9ed492a1-7d6f-11e3-9ccf-5404a6144203, is one of them. While we previously only documented a few, we’ve now found more that lead to the same exempt behavior.

We are updating our documentation to include this comprehensive list. But in the meantime, please refer to this updated table

Exempt Business Classifications

NAICS Code Business Classification Industry Classification UUID
522110 Financial services and products Commercial Banking 53FF176E-F832-4DB3-89F4-D8F7044184C7
5239 Financial services and products Other financial investment activities 9ED3CF71-7D6F-11E3-BF7B-5404A6144203
524126 Financial services and products Insurance - auto and home 9ED3CF6F-7D6F-11E3-BC97-5404A6144203
522130 Financial services and products Credit union 9ED3CF68-7D6F-11E3-8ABB-5404A6144203
812990 Religion and spirituality (for profit) Services not elsewhere classified 9ED44495-7D6F-11E3-B2F6-5404A6144203
812990 Services - other All other personal services 9ED444A1-7D6F-11E3-858E-5404A6144203
812990 Services - other Event and wedding planning 9ED46B9A-7D6F-11E3-A11B-5404A6144203
524126 Services - other Insurance - auto and home 9ED46BA3-7D6F-11E3-9EFE-5404A6144203
812990 Services - other Services not elsewhere classified 9ED492A1-7D6F-11E3-9CCF-5404A6144203

We sincerely apologize for the confusion this caused. Should we go ahead an re-enable the setting for your Account so you can continue onboarding Exempt BVCRs? We wanted to get your approval before enabling. Please let us know!

Thanks again for bringing this to our attention and helping us make our documentation better for everyone! Let me know if you have any other questions.

1 Like
11

Thanks for the updated information. We will need to make some updates on our end as well. Let’s not enable settings in prod as of now. We will reach out through email on enabling the settings.

One question since business classifications seems to be updated time to time, is it possible for us to keep track of these updates dynamically? Or how do we know if there is a new value or some old value got deleted.

12

Hi @Abhimanyu_Pandey, noted! That sounds good!

Our business Classifications very rarely get updated (the last time was , but in this case, it was just that we hadn’t fully documented all the IDs that were relevant to the UBO Exempt Flow, for which we apologize as that’s what caused this unexpected behavior.

If a value gets added/updated/removed in way that it would be breaking, we will add that to our Changelog. There is no dynamic tracking notifications sent from our system for it. However, you could keep the businessClassifications list saved to your DB, and compare it with the list from the API on a cadence. I would start with Monthly. You could also do it weekly, but more than that isn’t really required.

Hope this helps! We thank you for your understanding! :folded_hands:

13

Just to make sure, we use {{dwolla_base_url}}/business-classifications, and have businessClassifications list save in our db, correct me if i am wrong but i do not find any field that resembles whether a particular industryClassification under a businessClassification will go through exempt flow, in this api.
Also for the data with NAICS code (522110) from the api {{dwolla_base_url}}/business-classifications i see the UUID is a66f769a-b4ea-4c5a-a2aa-f8408fa0eac7, but the one you mentioned above is 53FF176E-F832-4DB3-89F4-D8F7044184C7 (the data on the first row). FYI i was cross checking the data in sandbox env.

14

Hi @Abhimanyu_Pandey, these IDs are for Prod! In Sandbox, you can try to test with the ID that corresponds to the relevant industry classification type.

There’s no indicator in the list from the API that tells that the codes are exempt, as it only applies to clients who are using the setting for UBO Exemption. This information is only documented in the docs that we’ve shared with you!