Draft Regulatory Impact Assessment Memorandum

---
name: draft-regulatory-impact-assessment-memorandum
task_id: corporate-governance/draft-regulatory-impact-assessment-memorandum
description: Agents summarize a proposed rule's provisions for a holding company and assess facility-level performance, data infrastructure implications, multi-regulator coordination, emerging community development qualification issues, and differential impacts across market types.
activates_for: [planner, solver, checker]
---

# Skill: Regulatory Impact Assessment Memorandum for a Proposed Banking Rule

## 1. Subject-matter triage

- Identify the proposal, the current baseline, and the institution perimeter before analyzing impacts.
- Separate consolidated holding company effects from subsidiary-bank effects; do not assume one level of analysis answers the other.
- If the source set contains multiple banks, branches, or assessment areas, enumerate them first and analyze each individually.
- If the comment period is open, flag the deadline and any board action needed to support a submission.
- If the task asks for a board-ready memo, treat the memo as the primary deliverable and make the analysis decision-oriented, not academic.

## 2. Failure modes the skill is correcting

- Baseline summaries describe the proposal at a high level but do not translate it into institution-specific operational, supervisory, and competitive consequences.
- Analysis stays consolidated when the rule turns on branch, facility, deposit, or assessment-area performance.
- The memo states that performance may change but does not compare current conditions to the proposal’s benchmarks or identify likely shortfalls.
- The memo notes data burden in the abstract but does not isolate geocoding, mapping, reporting, governance, training, and systems implications.
- The memo ignores that different subsidiaries may face different primary supervisors and therefore different implementation paths.
- The memo treats community development eligibility as settled when the proposal may expand, narrow, or reclassify qualifying activities.
- The memo overgeneralizes from large-urban conditions and misses that calibration may operate differently in rural, suburban, and urban markets.
- The memo describes risk without ending each issue with the source hook and the practical consequence for the institution.
- The memo gives analysis without converting it into board-ready recommendations.

## 3. Legal frameworks / domain conventions that apply

- **Community Reinvestment Act, 12 U.S.C. §§ 2901 et seq.**: Frame the rule as an implementation change to a statutory community credit obligation, not merely a reporting exercise.
- **Regulatory modernization proposal**: Identify which elements change measurement, assessment areas, benchmarks, or qualifying activities, and distinguish proposal text from current requirements.
- **Facility-, branch-, or deposit-based assessment logic**: Analyze the institution at the level the proposal uses for performance evaluation; one strong line of business does not offset a weak one if the rule evaluates separately.
- **Retail lending, investment, and community development tests**: Match each activity type to the proposal’s relevant standard and assess whether current activity appears sufficient under that standard.
- **Supervisory allocation under federal banking law**: Where subsidiaries are examined by different agencies, compare how each agency’s implementation path may differ and whether enterprise coordination is needed.
- **Data collection and address-mapping requirements**: Treat geocoding, source-system integrity, and ongoing QA as compliance infrastructure, not optional operations support.
- **Community development qualification concepts**: Test climate-, resilience-, housing-, small-business-, or infrastructure-linked activities only against the proposal’s actual eligibility criteria.
- **Market calibration principles**: Evaluate whether national or aggregated thresholds may create disproportionate effects across rural, suburban, and urban markets.
- **Comment-process conventions**: If the proposal is open for comment, identify advocacy points tied to calibration, administrability, supervisory consistency, and eligibility rules.

## 4. Analytical scaffolds

- **Rule-to-impact translation**: For each substantive proposal change, state what changes in day-to-day compliance, business planning, reporting, and supervisory exposure.
- **Per-entity analysis**: For each holding-company component or material subsidiary, assess likely impact separately, then synthesize enterprise-wide implications.
- **Benchmark comparison**: Compare current activity levels, portfolio mix, or community development posture to the proposal’s standard and identify likely gap areas.
- **Data burden mapping**: List each new data element, mapping step, or governance control implied by the proposal, then assess systems, staffing, timing, and quality risks.
- **Regulator coordination map**: Identify the primary supervisor for each subsidiary, flag any likely inconsistency in implementation, and note where a unified policy response is advisable.
- **Advocacy issue spotting**: Identify provisions that may warrant comment, especially those affecting measurement design, threshold calibration, qualifying activity definitions, or compliance burden.
- **Timing assessment**: Compare the proposed effective date and implementation milestones to the remediation timeline needed for data, policy, and business changes.
- **Board synthesis**: Convert technical findings into decision-relevant takeaways: exposure, preparedness, required investment, supervisory friction, and comment strategy.

## 5. Vertical / structural / temporal relationships

- Distinguish holding company exposure from bank-level exposure and do not collapse them into a single enterprise conclusion.
- Where a proposal applies differently by assessment area, branch network, deposit footprint, or market type, preserve that geographic stratification in the analysis.
- Where subsidiaries operate under different regulators, analyze the issue regulator-by-regulator before drawing an enterprise recommendation.
- Where the proposal introduces phased implementation or delayed compliance dates, anchor each recommendation to the relevant milestone rather than using a generic urgency label.
- Where the source set contains multiple documents, treat them as an integrated record and reconcile any inconsistencies before drafting the memo.

## 6. Output structure conventions

- Draft a board-ready memorandum with an executive summary, a concise description of the proposal, institution-specific impact analysis, supervisory coordination considerations, comment-period opportunities, recommended actions, and an implementation timeline.
- Use conventional memo headings rather than copying any checklist or rubric label.
- For issue-oriented sections, give each identified issue a uniform severity label using an ordinal scale defined once near the top.
- For each issue, state: the relevant proposal feature, the affected entity or market segment, the source-based benchmark or comparison point, the cross-document interaction that matters, and the downstream operational, regulatory, or strategic consequence.
- When multiple subsidiaries, markets, or activity types are in scope, present them in a numbered structure or table before analyzing them so each row can be tracked through the memo.
- Include a clear Recommended Actions section that assigns an owner and a timing anchor for each action.
- If the task requires a file output, ensure the memo is written as the operative product, not a summary of it, and that the final document is board-ready in tone and completeness.