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Agent packs

Compliance · Agent pack

Regulatory change analysis

Cadre pack · Marginalia

Turns a supplied rule change into candidate obligations, control mappings, gaps, and proposed actions for review.

Demonstrated on representative cases. Source coverage, thresholds, policy interpretation, escalation design, and performance require institution-specific validation.

Operating dossier

The job, permitted decisions, and owner

Mandate

Parses incoming regulation into structured, mapped obligations and surfaces control gaps.

Case arrives with
Reg ID · Section · Summary
Allowed outcomes
Structured outcome for review
Where it fits
Regulatory Change
Decision logic
  1. 01Breaks a supplied rule or amendment into candidate obligations, each retaining its source citation for legal and control-owner review.
  2. 02Maps those candidate obligations to the documented control inventory by scope, not keyword: a control is proposed as coverage only when its described reach extends there.
  3. 03Checks stated applicability first, so rules for other institution types are not silently credited against the bank's controls.
  4. 04Neither invents gaps nor assumes coverage; the output is a reviewable draft gap list with remediation actions a compliance officer can accept, change, or reject.
Must not
Invent missing evidence or act outside the permitted outcomes.
Human owner
Control ownership and legal interpretation
Evidence retained
Structured outcome, observed path, and the source evidence used.

Case and record

One case, from supplied evidence to recorded decision

Supplied case

Representative case dataSynthetic or simulated data
Reg ID
cfr 31 1020
Section
1020.220
Summary
Customer identification program (CIP) requirements for banks amended.
View the case data

Case key cip-1020.220

{
  "regId": "cfr-31-1020",
  "section": "1020.220",
  "summary": "Customer identification program (CIP) requirements for banks amended."
}

Recorded path and outcome

Cadre reference capture

One frozen, sanitized path through representative data. It is an inspection aid, not a performance claim.

Observed path

  1. Get regulation

  2. List controls

  3. Recorded the structured decision

  4. Record assessment

  5. Committed the contracted outcome

Recorded outcome

10 obligations · 8 gaps

Coverage

Open decision record

Evaluation and limits

Evaluation coverage and stopping points

Published evaluation map

Expected decisions, boundaries, and costly failure modes.

These cases show what the pack is asked to decide, when it should stop, and which plausible errors the evaluation is meant to expose. They are not a reliability score or independent validation.

Expected and borderline behavior

Routine judgments, close calls, and named stopping points.

  • CIP rule: controls cover collect/verify/recordkeep but NOT government-list screening or customer notice

    2 gaps.

    Case key

    cip-1020.220
  • SAR rule

    largely covered by the SAR control; obligations include filing, threshold, timing, confidentiality, recordkeeping.

    Case key

    sar-1020.320

Boundary and misuse cases

Plausible inputs that could produce a costly or overconfident decision.

  • AML program

    four pillars covered by CTRL-AML-01; the one real gap is risk-based ongoing CDD / beneficial ownership. Must not invent gaps for the covered pillars.

    Case key

    adv-1020.210-mostly-covered
  • AML program for MONEY SERVICES BUSINESSES, not banks

    Must flag the applicability/scope mismatch, not declare bank-control coverage.

    Case key

    adv-1022.210-applicability

Operating fit

Workflow placement and validation

Operating pattern

Independent review

Separate the work from the party that tests it, then require findings to point back to evidence and a named standard.

Decision sequence and workflow placement
  1. 01Receive completed work
  2. 02Reconstruct the standard
  3. 03Run independent checks
  4. 04State findings and limits
  5. 05Assign accountable review
Pattern guide

Institution-specific validation

These questions remain open until the pack is fitted to an institution.

Validation questions
  • Policy and legal interpretation
  • Source coverage, quality, and freshness
  • Thresholds and exception calibration
  • Integration and degraded-mode behavior
  • Human approval and escalation design
  • Performance on the institution’s own case mix