Declaration Lifecycle¶
Overview¶
A declaration in Regnify represents a representative appointment form (3A, 3B, or 3C) as it moves through the full lifecycle — from initial creation by the representative, through internal multi-level approval, Fit and Proper assessment, and ultimately MAS submission and approval. Each declaration passes through a defined set of status states with specific rules governing transitions, permissions, and blocking conditions.
Status States¶
Complete Status Flow¶
+-----------------------+
| |
v |
Draft --> Pending Review --> Approved --> Good --> MAS_PENDING_REVIEW --> MAS_APPROVED
| | |
v v v
Rejected Rejected MAS_REJECTED
| | |
v v v
(re-editable) (re-editable) (re-editable)
Status Definitions¶
| Status | Description | Who Can Act | Editable |
|---|---|---|---|
| Draft | Initial state; representative is filling in the form | Representative | Yes |
| Pending Review | Submitted for approval; moving through the approval chain | Current approver | No (except via send-back) |
| Approved | All internal approvers have approved | Compliance officer | No |
| Good | Fit and Proper assessment confirmed; ready for MAS submission | Authorized officer | No |
| MAS_PENDING_REVIEW | Lodged with MAS; awaiting MAS decision | MAS (external) | No |
| MAS_APPROVED | MAS has accepted the representative appointment | N/A (terminal) | No |
| Rejected | An approver has rejected the declaration | Representative | Yes |
| MAS_REJECTED | MAS has rejected the submission | Representative | Yes |
Stage 1: Draft¶
Entry Conditions¶
- Representative creates a new declaration
- Or a rejected/MAS-rejected declaration is re-opened for editing
What Happens in Draft¶
- The representative selects form type (3A, 3B, or 3C)
- Form sections are filled in progressively (9 sections for Form 3A)
- Auto-save runs every 30 seconds, persisting form data without status change
- Supporting documents can be uploaded and managed
- The declaration can be saved and returned to at any time
Exit Conditions¶
- Representative clicks "Submit for Review"
- Validation requirements before submission:
- All mandatory form fields must be completed
- At least 1 supporting document must be attached
- No other non-Draft declaration exists for this representative (blocking rule)
Blocking Rule¶
A representative cannot submit a new declaration if any of the following exist: - Another declaration in Pending Review status - Another declaration in Approved status - Another declaration in Good status - Another declaration in MAS_PENDING_REVIEW status
This prevents duplicate or conflicting submissions for the same representative. The representative must wait for the existing declaration to reach a terminal state (MAS_APPROVED, Rejected, or MAS_REJECTED) or be withdrawn before submitting a new one.
Stage 2: Pending Review¶
Entry Conditions¶
- Representative submits the declaration from Draft status
- Or representative resubmits after a send-back revision
What Happens During Review¶
- A workflow instance is created from the workflow template
- The declaration moves through up to 6 sequential approval steps
- Each approver reviews the declaration and can:
- Approve: Advances to the next step
- Reject: Returns to the representative with reasons
- Send back for revision: Requests specific changes
Send-Back Sub-Flow¶
When an approver sends back for revision: 1. The declaration returns to the representative for editing 2. The representative makes corrections 3. Upon resubmission, the declaration returns to the same approver (not step 1) 4. Previous approvals from earlier steps are retained
Overdue Detection¶
- Declarations in Pending Review for more than 5 business days trigger overdue indicators
- Approver and admin dashboards display color-coded days-pending
- Overdue declarations are flagged for escalation
Exit Conditions¶
- All approvers approve -> Status changes to Approved
- Any approver rejects -> Status changes to Rejected
Stage 3: Approved¶
Entry Conditions¶
- The final approver in the workflow chain approves the declaration
What Happens After Approval¶
- All approvers and the representative are notified
- The compliance officer conducts or confirms the Fit and Proper assessment
- The assessment covers:
- Criminal record check
- Bankruptcy check
- Regulatory action history
- Educational qualifications verification
- CMFAS examination requirements
- Character assessment
Exit Conditions¶
- Fit and Proper assessment satisfactory -> Status changes to Good
- Fit and Proper issues found -> Status changes to Rejected (returns to representative for remediation)
Stage 4: Good¶
Entry Conditions¶
- The Fit and Proper assessment is confirmed satisfactory
What Happens at Good Status¶
- The declaration package is finalized
- All form data and supporting documents are verified as complete
- The authorized officer (typically compliance or CEO) prepares for MAS submission
- The form is ready to be lodged in the MAS CoRe system
Exit Conditions¶
- Authorized officer lodges form with MAS -> Status changes to MAS_PENDING_REVIEW
Current Process¶
In the current Regnify implementation, MAS submission is a manual step: 1. The authorized officer downloads or views the finalized declaration 2. Logs into MAS CoRe system 3. Manually enters or uploads the form data 4. Pays the $200 lodgement fee 5. Updates the declaration status in Regnify to MAS_PENDING_REVIEW
Stage 5: MAS_PENDING_REVIEW¶
Entry Conditions¶
- The form has been lodged with MAS via the CoRe system
What Happens During MAS Review¶
- MAS reviews the submission within 14 business days
- MAS may raise queries through CoRe (the principal must respond within the specified timeframe)
- The declaration cannot be edited in Regnify during this period
Exit Conditions¶
- MAS approves -> Status changes to MAS_APPROVED
- MAS rejects -> Status changes to MAS_REJECTED
Stage 6: MAS_APPROVED (Terminal)¶
Entry Conditions¶
- MAS has accepted the representative appointment
What Happens After MAS Approval¶
- The representative is registered on the MAS public register (Financial Institutions Directory)
- The representative is authorized to conduct the declared regulated activities
- Annual representative fees begin accruing
- The declaration reaches its terminal state — no further status changes
Post-Approval Obligations¶
- Principal must notify MAS of any changes to the representative's particulars
- Annual Fit and Proper declarations are required
- Annual representative fees must be paid
Rejection Paths¶
Internal Rejection (During Pending Review)¶
Trigger: Any approver in the chain rejects the declaration
Impact: - Status changes to Rejected - The rejection reason and comments are recorded - All workflow progress is voided — if re-submitted, the declaration restarts from step 1 - The representative is notified with the specific rejection reason
Recovery: 1. The representative reviews the rejection reason 2. The declaration becomes editable 3. The representative makes necessary corrections 4. Re-submission creates a new workflow instance starting from step 1 5. All approvers must review again
Internal Rejection (After Approval — Fit and Proper Failure)¶
Trigger: The Fit and Proper assessment reveals issues
Impact: - Status changes to Rejected - The declaration returns to the representative with compliance findings - May require additional documentation or remediation
Recovery: - Address the Fit and Proper concerns - Provide additional documentation or explanations - Re-submit for full re-approval
MAS Rejection¶
Trigger: MAS declines the appointment submission
Impact: - Status changes to MAS_REJECTED - MAS provides rejection reasons through the CoRe system - The declaration becomes re-editable in Regnify
Common MAS Rejection Reasons: - Incomplete or inconsistent information - Failed CMFAS examination requirements - Adverse Fit and Proper findings - Incomplete supporting documentation - Discrepancies between submitted information and MAS records
Recovery: 1. Review the MAS rejection reasons 2. Address each issue identified 3. The declaration returns to Draft-like state (re-editable) 4. After corrections, the declaration must pass through the full internal approval workflow again 5. Once re-approved, re-lodge with MAS
Status Transition Matrix¶
| From | To | Trigger | Actor |
|---|---|---|---|
| (new) | Draft | Create declaration | Representative |
| Draft | Pending Review | Submit for review | Representative |
| Pending Review | Approved | All approvers approve | Final approver |
| Pending Review | Rejected | Any approver rejects | Approver |
| Pending Review | Pending Review | Send-back and resubmit | Approver + Representative |
| Approved | Good | Fit and Proper confirmed | Compliance officer |
| Approved | Rejected | Fit and Proper failed | Compliance officer |
| Good | MAS_PENDING_REVIEW | Lodge with MAS | Authorized officer |
| MAS_PENDING_REVIEW | MAS_APPROVED | MAS accepts | MAS |
| MAS_PENDING_REVIEW | MAS_REJECTED | MAS declines | MAS |
| Rejected | Draft | Re-open for editing | Representative |
| MAS_REJECTED | Draft | Re-open for editing | Representative |
Audit Trail¶
Every status transition is recorded in the audit log with: - Timestamp: When the transition occurred - Actor: Who performed the action (user ID and role) - From status: Previous status - To status: New status - Comments: Approver comments, rejection reasons, or revision notes - Declaration ID: Unique identifier of the declaration
The audit trail combined with workflow step data forms a unified declaration history timeline, providing full traceability from creation through MAS outcome.
Key Business Rules Summary¶
- One active declaration per representative: Only one non-Draft declaration allowed at a time
- Minimum 1 document: At least one supporting document required before submission
- Auto-save in Draft: Form data persists every 30 seconds
- Sequential approval: Approvers must act in order
- Send-back preserves progress: Prior approvals are retained on send-back
- Rejection resets progress: Full re-approval required after rejection
- 5-day overdue threshold: Pending declarations flagged after 5 business days
- Skeleton data for third parties: Vendors see redacted information only
- Re-editable terminal states: Rejected and MAS_REJECTED allow re-editing
- MAS_APPROVED is final: No further status changes after MAS approval