Request Documents for Application Review

In some cases, an Application may be flagged for manual review because additional verification information is needed from the Account Holder to confirm the identity of the Person or Business and comply with Know-Your-Customer (KYC) or Know-Your-Business (KYB) regulations.

If your customer’s Application enters IN_REVIEW, you may need to collect additional documentation to complete the process. An Application with a status of IN_REVIEW will contain details on the need for additional verification. If documents are required, you can use the Highnote API to generate upload URLs and allow customers to provide documents from your UI. If an application is IN_REVIEW but does not require identity documents, you can simply notify your customer that their application is under review.

Once your Account Holder has uploaded their verification documents, a Highnote agent will review the documents and take the following actions:

• Approve the Application as the documents sufficiently confirm the identity of the Account Holder
• Decline the Application as the documents were not provided or appear to be fraudulent or forged

Documents must not be expired and supporting documents must be dated within 60 days. If the document appears forged, is outdated, and/or is otherwise invalid, the Application will be DENIED.

Individual, Controller, or Beneficial Owner Identity Documentation

Depending on the response, the Account Holder must provide one of relevant document(s) listed below. When there are multiple response codes, the Account Holder may need to provide multiple documents.

Business Entity Documentation

Depending on the response, the Account Holder must provide one of relevant document(s) listed below. When there are multiple response codes, the Account Holder may need to provide multiple documents.

For Sole Proprietors, given an FEIN document may not available, only one of the following documents would need to be uploaded:

• Taxpayer identification
• Social Security Card
• Owner’s Full Tax Return with Schedule C included

In the case an Application has been flagged for manual review and verification documents are required, you can use the Highnote API to generate upload URLs and allow customers to provide documents from your UI.

One or more documents may be required based on the type of documentation they are providing.

A document upload session expires 30 days from creation. If the Account Holder does not provide the required documentation within 30 days, the application will be DENIED.

To begin the process of uploading your user’s documents to Highnote’s secure document store, use the startDocumentUploadSession. A session allows you to upload multiple documents within a given time frame.

A session will also indicate to you any requirements that may need to be enforced by your system when uploading the file.

Note: To make requests direct from your client, you will first need to generate a Client Token.

Document upload links expire 5 minutes after creation.

Create a secure upload link for each file the applicant wishes to upload to Highnote’s secure document store. Each link represents a single file to be uploaded. The response contains a field called documentUploadSecureLink which you can use to stream the file upload.

Once your user has confirmed that they have uploaded all required documents, call endDocumentUploadSession to end the session. When a session is ended, the status of the session will be reflected as SUBMITTED. A Highnote agent will review the provided documents and decision the application once the status of the session is SUBMITTED.

Note: No other actions can be taken against this session once the status is reflected as SUBMITTED. If it is determined that more documentation is required, a new session must be started to upload the additional documents.

Highnote will not return a public link to access the content of the documents to best protect the Account Holder's privacy.

You can check the requiredDocuments status on the application to see if the document upload was completed by the applicant.

You can check the uploadedDocuments field on the requiredDocuments for the document types that were uploaded by the applicant.

Once verification documents have been uploaded, you can query for the status.

Verification documents are reviewed by a Highnote agent. You can query for the review status.

The Test Environment does not run KYB (Know Your Business) and KYC (Know Your Customer) checks on Applications. When testing, you can simulate Application failure under a variety of scenarios by creating Account Holders with specific attribute values. The simulation will produce Tags associated with the application decision and provide information as to why an Application outcome was APPROVED, IN_REVIEW, or DENIED.

For KYC, regulation requires that we collect the person’s name, address, date of birth, and identification number (e.g. SSN). For KYB, regulation requires that we collect a Business' EIN / FEIN, the Business name, Business address, and identifying information of any Ultimate Beneficial Owners (UBOs).

Note: All values, except failure values, will trigger the attributes associated with Pass Tags.

KYC Identity Verification Simulation (Person Account Holders)

The following fields and associated values will simulate DENIED and IN_REVIEW application states.

The following fields and associated values will simulate various tags associated with the application decision.

KYB Identity Verification Simulation (Business Account Holders)

The following fields and associated values will simulate DENIED and IN_REVIEW application states.

The following fields and associated values will simulate various tags associated with the application decision.

Please see Identity Verification Overview for more information on customer identity programs, application outcomes, and onboarding tags.

Once an Application for a Person Account Holder, Primary Authorized Person, Ultimate Beneficial Business Owner (UBO) or Business has entered Manual Review with a status of IN_REVIEW, you can begin a document upload session to simulate adding supporting documents:

1. Generate a Client Token (integration specific)
2. Start Document Upload Session
3. Create Document Link
4. End the Document Upload Session

Once you've closed the document upload session, you can simulate the outcome of the Document Review as if each document was reviewed by a Highnote Agent by assigning a new status of APPROVED or DENIED.

In some cases, the document(s) provided by the Account Holder may be insufficient to approve the application. If the Account Holder needs to upload additional documents after documents were previously submitted, a new document upload session will be created for the Account Holder to upload a new document type(s).

In the Test Environment, you can simulate requesting a second document upload session for an application. The request input will need to include specific document types.

Once the request is simulated, the status of the application will be DOCUMENT_UPLOAD_REQUIRED. Multiple applicants under the same application can be selected and multiple document types can be requested for each applicant.

A second upload session will trigger the CARD_PRODUCT_APPLICATION_DOCUMENT_UPLOAD_REQUESTED notification event. The event allows you to create a unique communication template to your Account Holders when documents are requested a second time for their application versus the first time documents are requested.

Once you've uploaded supporting documents for an Identity and simulated a review of each document, you can simulate the outcome of Identity Verification as if reviewed by a Highnote Agent. This will transition the Identity Verification from a status of IN_REVIEW to PASSED, DENIED or DOCUMENT_UPLOAD_REQUIRED if you want to test your flow for requiring additional documents.

You may also simulate the outcome of an entire Application without the document upload or identity verification steps and transition the Application's status from IN_REVIEW directly to APPROVED or DENIED.