Internal Approval Workflow for Representative Appointment¶

Before a representative appointment form (3A, 3B, or 3C) is submitted to MAS via the CoRe system, it must pass through the financial institution's internal approval workflow. This multi-level approval chain ensures that the appointment meets all internal compliance policies, regulatory requirements, and organizational standards before external submission.

Regnify implements a configurable approval workflow engine supporting up to 6 sequential approvers per declaration.

Role Hierarchy¶

The approval chain follows an organizational role hierarchy with escalating authority levels.

Approval Ranks¶

Rank	Role	Typical Responsibilities
1	Representative (FI_USER)	Initiates declaration, fills Form 3A/3B/3C
2	Supervisor	First-level review, verifies completeness and accuracy
3	Manager	Departmental approval, confirms business need
4	CEO / Senior Management	Final organizational sign-off

Compliance Officer Role (COMP)¶

The Compliance Officer operates outside the standard rank hierarchy and may be assigned at any approval step: - Reviews regulatory compliance aspects - Validates Fit and Proper assessments - Confirms CMFAS examination requirements are met - May be required at multiple steps in the chain

HR Administrator Role (HR_ADMIN)¶

HR administrators support the process by: - Verifying employment records and background checks - Confirming educational qualifications - Providing reference check results - May be assigned as an approver at an early step

Organization Administrator Role (ORG_ADMIN)¶

Organization administrators manage the workflow configuration: - Create and modify workflow templates - Assign approvers to workflow steps - Monitor workflow progress across the organization

Workflow Template Configuration¶

Template Structure¶

Each workflow template defines the approval chain for a specific combination of: - Representative: The individual being appointed - Form type: 3A, 3B, or 3C - Organization: The CMS licensee or LFA

A template consists of ordered steps, each assigned to a specific approver.

Template Rules¶

Unique per representative and form type: Each (representative, form_type) combination has exactly one active workflow template
Maximum 6 steps: A workflow template supports up to 6 sequential approval steps
Unique approvers: The same person cannot be assigned to multiple steps within the same template
Approver eligibility: An approver must:
Be from the same organization as the representative
Have a higher approval rank than the representative
Have the is_approver flag set to true in their profile
Be in the same domain (business unit) as the representative

Example Workflow Templates¶

Small firm (3 steps): 1. Supervisor — Initial review 2. Compliance Officer — Regulatory check 3. CEO — Final approval

Large firm (6 steps): 1. Direct Supervisor — Completeness check 2. Department Manager — Business justification 3. HR Manager — Background verification 4. Compliance Analyst — Preliminary compliance check 5. Chief Compliance Officer — Final compliance review 6. CEO — Organizational sign-off

Regnify seeded Form 3A chain (4 steps): Supervisor → Manager → CEO → Compliance. The CEO step sits before Compliance, so MAS submission is gated behind CEO sign-off — because steps are sequential and the declaration only reaches Cleared for MAS Submission on the final (Compliance) approval, Compliance cannot act, and MAS cannot be reached, until the CEO step is approved. CEO users are FI_USER with org role "CEO" (approval rank 4, is_approver=true); HR_ADMIN is not an approver tier. (The quarterly attestation chain stays Supervisor → Manager → Compliance, with no CEO.)

Approval Workflow Lifecycle¶

Step-by-Step Process¶

1. Declaration Creation (Representative)¶

The representative (FI_USER) creates a new declaration: - Selects the appropriate form type (3A, 3B, or 3C) - Fills in all required sections of the form - Uploads supporting documents (minimum 1 required) - Auto-save runs every 30 seconds during editing - Status: Draft

2. Declaration Submission (Representative)¶

When the form is complete: - The representative clicks "Submit for Review" - System validates all required fields are completed - System checks no other non-Draft declaration exists for this representative (blocking rule) - The workflow instance is created from the workflow template - The first approver in the chain is notified - Status changes: Draft -> Pending Review

3. Sequential Approval (Approvers)¶

Each approver in the chain reviews the declaration in order:

For each step, the approver can:

Approve: Advances to the next step (or completes the workflow if it's the last step)
The next approver is notified automatically
The representative receives a notification of step progress
Reject: Sends the declaration back with comments
Status changes to: Rejected
The representative is notified with the rejection reason
The declaration becomes re-editable for the representative
Send Back for Revision: Requests changes without full rejection
The declaration returns to the representative for editing
The approver specifies what needs to be changed
After revision, the representative resubmits
The declaration re-enters the approval chain at the step that sent it back (not from the beginning)

4. Workflow Completion¶

When the final approver in the chain approves: - Status changes: Pending Review -> Approved - The representative and all approvers are notified - The declaration is ready for Fit and Proper assessment

5. Fit and Proper Check¶

After internal approval: - The compliance officer conducts or confirms the Fit and Proper assessment - If satisfactory, status changes: Approved -> Good - The declaration is now ready for MAS submission

6. MAS Submission¶

The authorized officer lodges the form with MAS via CoRe: - Status changes: Good -> MAS_PENDING_REVIEW - Upon MAS approval: MAS_PENDING_REVIEW -> MAS_APPROVED - If MAS rejects: MAS_PENDING_REVIEW -> MAS_REJECTED (re-editable)

Send-Back and Revision Flow¶

How Send-Back Works¶

An approver identifies an issue that can be corrected (e.g., missing information, typo, incorrect date)
Instead of rejecting, the approver selects "Send Back for Revision"
The approver provides specific revision comments explaining what needs to change
The declaration returns to the representative

Representative Revision Process¶

The representative receives a notification with the revision request
The declaration becomes editable again
The representative makes the requested changes
The representative resubmits with a note explaining the changes made
The declaration returns to the same approver who sent it back (not step 1)

Key Difference: Send-Back vs Rejection¶

Aspect	Send-Back	Rejection
Severity	Minor issues, corrections needed	Major issues, fundamental problems
Re-entry point	Same approver who sent it back	Back to the representative (restart workflow)
Prior approvals	Retained (previous steps don't need to re-approve)	Voided (full re-approval required)
Typical use	Missing document, typo, unclear explanation	Ineligible representative, failed Fit and Proper

Workflow Status Tracking¶

Declaration Status States¶

Draft
  |
  v
Pending Review  <-->  Sent Back for Revision (re-editable by representative)
  |         |
  v         v
Approved   Rejected (re-editable by representative)
  |
  v
Good (Fit and Proper confirmed)
  |
  v
MAS_PENDING_REVIEW
  |         |
  v         v
MAS_APPROVED   MAS_REJECTED (re-editable)

Workflow Instance Tracking¶

Each workflow instance tracks: - Current step number (1 through N) - Status of each step (pending, approved, rejected, sent_back) - Approver assigned to each step - Timestamp of each action - Comments from each approver - Revision history (if send-back occurred)

Notifications¶

Notification Triggers¶

Event	Notified Party
Declaration submitted	First approver
Step approved	Next approver + representative
All steps approved	Representative + all approvers
Rejection	Representative
Send-back for revision	Representative
Revision resubmitted	Approver who sent it back
MAS approval	Representative + compliance officer
MAS rejection	Representative + compliance officer

Overdue Detection and SLA Benchmarks¶

The Regnify dashboard surfaces all pending declarations at a glance and flags any declaration that has been in Pending Review for more than 5 business days as overdue. Approver and admin dashboards display these overdue declarations with color-coded days-pending counters showing time elapsed since the last status change, so reviewers can spot bottlenecks without opening individual declarations. A practical internal SLA is 2-3 business days per approval step (5-10 business days total for a typical chain), aligned with the 5-day overdue flag. After internal approval, MAS review takes 14 business days under the standard CoRe processing window — internal SLAs should be tight enough to leave headroom for that external clock plus any MAS query response (typically 7 business days).

Declarations pending review for more than 5 business days are flagged as overdue
Overdue indicators appear on approver and admin dashboards
Color-coded days-pending shows time elapsed since last status change
After internal approval, MAS review: 14 business days (standard CoRe processing window)

Business Rules and Constraints¶

Declaration blocking: A representative cannot submit a new declaration if another non-Draft declaration exists in the approval chain
Document minimum: At least 1 supporting document must be attached before submission
Auto-save: Form data auto-saves as Draft every 30 seconds during editing
Skeleton data: Third-party vendors viewing the declaration see redacted (skeleton) data only
Reporting officer: The assigned reporting officer must be from the same domain, have a higher approval rank, and have is_approver=true
Unique workflow per declaration: Each declaration has exactly one active workflow instance
Sequential processing: Approvers must review in order — step 3 cannot approve before step 2