Identity Decisioning Workflow

Upon submission of an application in our Account Opening product, all applicant information, in addition to other information we collect on the application, is processed through an identity decisioning workflow. Our Alloy evaluation workflow results in an application being approved, denied, or sent to manual review depending on the criteria that your financial institution has set with Alloy. Typically, all applications undergo the same evaluation workflow. However, this can be customized. Go to Alternative Alloy Workflow for more information.

Note: If your institution uses Consumer Account Opening in Digital Banking, those Digital Banking users are NOT sent to Alloy for identity decisioning. Since they are currently active customers of your institution, and already logged in when applying, this allows faster opening of additional accounts.

Evaluating Consumers

For consumers, we evaluate the application as a Group entity that contains either a single Person entity or two Person entities (if the application is a joint application). Based on how these Person entities are decisioned, a final decision is made on the Group, and the decision on the Group represents the decision on the application.

Evaluating Businesses

For businesses, we still evaluate the application as a Group, but the contents of the Group are slightly different from a consumer Group. A business Group will contain a Person entity for every Beneficial Owner that was included in the application. In terms of decisioning, each of these Persons will be run through an Individual KYC workflow. This workflow is typically the same workflow that is used for consumer applications (recommended by Alloy), however, we do support individual workflows for business vs. consumer applications, which can be set up in the Alloy Portal. Please contact your Narmi Implementation Manager for assistance.

Additionally for KYB, the Group entity will also include a Business entity that is decisioned in a separate Business Workflow, which includes sending information about the business to Middesk. Based on outcomes for each Person entity and for the Business entity, the Group can then be decisioned.

Note: Sole Proprietor applications are evaluated using the consumer workflow rather than the business flow because they typically lack EINs and other information required to evaluate a business by Middesk.

Evaluation Data

Upon application submission, we send data to Alloy, which conducts KYC and KYB (via Middesk). Alloy uses the KYC data points to verify each consumer or owner/representative of the business, and then they send the relevant KYB data points to Middesk to complete the business verification. After evaluation, Alloy then returns an application state to us. 

Note: the application state returned will be for the Group (a combination of decisions for each owner and the business).

We send the following data to Alloy:

KYC

For every consumer or owner/partner in an organization, we send:

• First Name

• Last Name

• Phone Number

• Email Address

• Social Security Number/Individual Taxpayer Identification Number (ITIN)

• Date of Birth

• Primary Residential Address (line 1, line 2, city, state, postal code, country code)

KYB

For every LLC, partnership, or corporation, we send:

• Business Name

• Business Address (line 1, line 2, city, state, postal code)

• Business Employer Identification Number (EIN)

• Business Phone Number

• List of Business Representatives (a list containing each individual that was included in the Ownership page)

  • Each representative includes:

    • First Name

    • Last Name

    • Type (beneficial owner or authorized signer; the person who is actually applying can be an authorized signer or beneficial owner, and every other owner must be a beneficial owner)

    • List of addresses (we only populate this with the applicant’s primary address)

Note: We do not send any uploaded business documents to Alloy.

Narmi and Alloy support customization of your KYC/KYB flow by selecting specific attributes to include in your evaluations. This can be done directly in the Alloy Portal.

Application Outcomes

After we send the data to Alloy, Alloy responds with one of the following outcomes:

• Approved – If we receive an "approved" state, we proceed with payment processing and send the applicant an email confirmation.

• Manual Review – If we receive a "manual review" state, we pause the application and send the applicant an email notification. The application must be manually decisioned by your financial institution in the Alloy platform. If an application is manually decisioned into an “approved” state, Narmi proceeds with payment processing.  

• Denied (Consumers or owners/partners in an organization only) – If we receive a “denied” state, we stop the application from proceeding and send the applicant an email notification. Please note, a denied applicant cannot be moved to the approved state by your financial institution, they must re-apply. Businesses are not auto-denied.

For more information on the emails we send to applicants, go to End-User Communications.

Identity Evaluation Record

The identity evaluation record of a specific applicant can be accessed via Applications in our Admin Platform. This link will take you to Alloy, which houses the identity workflow and record of the identity evaluation. Go to Admin Applications for more information.

For more information on the emails we send to applicants, go to End-User Communications.