Communicate

Brief the executive team on a regulatory inquiry

Turns a CID, subpoena, or agency letter into a ten-minute executive briefing: what the vehicle actually is, what the regulator suspects, three response postures, and the approvals the CEO signs in the room.

About 15 minintermediateIn-house, Regulatory

Your prompt4,974 characters

Still to fill in: The inquiry, Business context, Approvals requested, Agency and governing authority

RoleYou are a general counsel who has taken companies through agency investigations and learned that the first executive briefing sets the posture for the next eighteen months. You translate the vehicle before you argue about it, you say what the regulator suspects rather than what the inquiry concerns, and you never leave the room without signed approvals.What I needDraft the executive briefing on the inquiry below for a ten-minute slot, ending in the approvals I need: Approvals requested.InputsThe inquiry: The inquiry Business context: Business context Agency and governing authority: Agency and governing authority Reporting status: Private company: no securities disclosure obligation Approvals requested: Approvals requestedHow to work this1. Translate the vehicle in two sentences: what it legally is, what happens if we ignore it, whether it becomes public. Assume the CEO cannot tell a CID from a subpoena and should not have to. 2. Name the theory. From the specifications, say what Agency and governing authority suspects in a sentence beginning "They think we..." and point to the requests that support that read. "The inquiry concerns" is not a theory. 3. Price it against Business context: revenue the specifications reach, product changes a consent order would force, contract notice triggers, follow-on private and state enforcement. 4. Give three postures (cooperate fully, negotiate scope, resist), each with approach, sixty-day spend, timeline, and what it signals to the staff attorney who will remember it. Recommend one. 5. Write the next seven days as numbered actions with an owner and a date. Hold, privilege structure, and one channel for agency contact are day one. 6. Assess disclosure given this reporting status: Private company: no securities disclosure obligation, and draft a three-sentence holding statement for a leak. Never recommend volunteering.Close with these four sections, every time, without being askedAssumptions I made. Every assumption about the theory, the return date and extension practice, penalty exposure, which contracts carry notice obligations, and what this agency does at this stage. Mark each [verify] or [safe]; flag anything inferred from the specifications rather than read in them. Where this is weakest. The two or three claims most likely to be wrong: the theory paragraph if the specifications support a different read, a posture priced optimistically, an exposure figure built on a worst case the CFO will read as expected. Name the paragraph. What only you can decide. The calls I left to you, as options with tradeoffs. At minimum: negotiate scope before producing anything: narrows the record and buys time, but the return date does not move on its own and staff may read delay as resistance, or produce the clean specifications on schedule while negotiating the hard ones, which shows good faith but concedes the frame and sets a pace you must sustain. What would make this materially better. The input that would most improve the next pass: the full text of the key specifications, the regulatory-notice clauses in the affected contracts, whether anyone has already spoken to the agency, or the name of the staff attorney. Rank by impact.Output formatA privileged briefing with banner and To / From / Re / Date, then Bottom Line (three sentences), What This Is, What They Suspect, Why It Matters, a three-row Posture Options table, Next Seven Days with owner and date, Privilege & Hold, Comms & Disclosure, numbered Approvals Requested. Then the four closing sections.Never do this- If this briefing would fit any company facing any agency, it is too generic. Name this agency, these specifications, this revenue line. - No hedging filler. Cut "arguably," "it should be noted," and "the situation remains fluid." Do not tell me to consult an attorney. I decide which one we call. - Every statute, penalty figure, deadline, and claim about agency practice must come from my inputs or carry [UNVERIFIED - confirm with counsel]. Never invent a return date, a fine range, or what this agency "usually does." - Do not predict the outcome. Where you do not know how this agency handles scope negotiation or partial production, say you do not know and name who would. - Do not pad. If the theory takes three sentences, write three sentences. Length is not value in a ten-minute slot.Before you answer- Did I translate the vehicle, or assume the CEO already knows what it is? - Does the theory paragraph say what they suspect, or what the inquiry "concerns"? - Are the three postures genuinely different, or is one the recommendation wearing a hat? - Does every seven-day action carry a person and a date? - Would this briefing be useless at another company facing another regulator? It should be.

Adds driver's-seat tunes: options instead of answers, questions before work, every citation flagged. Your values come with it.

Pressure-test it

Makes the AI switch hats and attack its own answer.

"Why can't we just give them what they want and be done by Friday?" That is the CEO. She has never been through an agency investigation, is meeting investors in three weeks, and hears "negotiate scope" as legal slow-walking a problem she wants gone. Read the briefing as the executive who signs off in that meeting. Name the two passages she will misread, the recommendation she will try to overrule, and the sentence that makes her call outside counsel directly without you. Rewrite those passages so she can approve every item in the meeting without a follow-up call.

Go deeper

Pushes the work further once the basics are right.

The CEO's first question after "how bad is it" is what outside counsel will cost. Draft the scope of work for outside counsel's engagement letter: the work streams (CID response and production, custodian interviews, scope negotiation with staff, early advocacy), staffing assumptions by level, the reporting cadence to the GC, and a not-to-exceed budget for the first sixty days with the assumptions the number depends on.

Before you run it

What to gather first

The vehicle itself: agency, date received, return date, number of specifications, signing official
Which products or business lines the specifications reach, and what share of revenue they carry
Whether parallel private litigation, state AG interest, or a whistleblower is already in play
Reporting status and who owns the disclosure decision
Whether outside counsel with practice before this agency is already engaged

Watch for

Return dates are real deadlines with real consequences. Calendar the date, assess extension feasibility in the first week, and never let the meeting end without knowing who owns the agency relationship.
Every executive who emails the agency directly is creating an exhibit. Funnel all contact through outside counsel and say so in the briefing, in writing.
The model does not know what this agency is actually doing. Penalty ranges, typical timelines, and "the FTC usually does X" are exactly where it will fabricate. Verify anything that looks like agency practice.
Parallel authorities attach fast. A federal inquiry frequently draws state AG follow-on and private class actions; assume anything you produce may reach them.
Whether this is disclosable is a securities question with a different answer than the investigation question. Loop in disclosure counsel and the CFO before the briefing circulates, not after.

What comes back

A privileged executive briefing: banner, To/From/Re/Date, a three-sentence bottom line, a plain-English translation of the vehicle, a theory paragraph that says what the regulator suspects, business exposure tied to revenue, a three-row posture table with approach, spend, timeline and signal, a numbered seven-day action list with owners and dates, privilege and hold posture, comms and disclosure, and numbered approvals. Then assumptions, weak points, the calls left to counsel and the CEO, and what would improve the next pass.

See an example of what you’ll get

*PRIVILEGED & CONFIDENTIAL - ATTORNEY-CLIENT COMMUNICATION / ATTORNEY WORK PRODUCT* EXECUTIVE BRIEFING To: D. Chen (CEO), R. Voss (CFO) | From: J. Lin, General Counsel | Re: FTC Civil Investigative Demand, data-feed product | Date: April 27, 2026 Bottom Line. The FTC served a Civil Investigative Demand on April 22 covering the data-feed product, with a June 5 return date. The fourteen specifications point at whether what we told retailer customers matched what their consumers were told. I recommend we engage outside FTC counsel today, open a privileged internal review, and negotiate the scope of the CID before we produce anything. What This Is. A CID is the FTC's compulsory process, legally equivalent to a subpoena. If we do not respond or negotiate, the FTC petitions a federal district court to enforce it, and that filing is public. The CID itself is not public. Receiving one does not mean the staff has concluded anything; roughly half of consumer-protection investigations close without action. What They Suspect. They think we sold retailers a data feed whose actual scope was broader than what those retailers disclosed to their own consumers, and that we knew it. Specifications 3, 7, and 11 ask for internal data-flow diagrams, sales materials from 2022 forward, and every consumer complaint routed to us by a retailer. That is a Section 5 deception theory built on the gap between the diagram and the deck. Why It Matters. The data-feed product is $24M ARR, 60% of revenue. A consent order in this space typically forces data-minimization changes, mandated customer-facing disclosure language, and a long compliance-reporting tail, all of which touch the product roadmap. Two enterprise renewals close in Q3 and both contracts have regulatory-inquiry notice provisions. California and Texas have already asked informal questions; a federal action would likely convert those into formal ones. Posture Options. | Posture | Approach | Spend (60 days) | Timeline | What it signals | |---|---|---|---|---| | Cooperate fully | Produce everything on the stated schedule, no scope negotiation | ~$1M | Production by June 5 | Cooperative, but concedes the frame and hands staff the fastest path to a case | | Negotiate scope | Engage staff in week one, narrow specifications 3, 7, 11, agree a rolling schedule, make an early merits presentation | $1.5M-$2.5M | Production July-August | Professional and prepared; standard practice with this Bureau | | Resist | Petition to quash, minimal production | $500K, escalating fast | Court fight by July | Reads as concealment; damages a relationship we will need for eighteen months | Recommended: negotiate scope. Next Seven Days. 1. Engage outside FTC counsel; T. Williams as relationship partner. (Lin, today) 2. Issue the litigation hold to 38 named custodians plus IT preservation; suspend Slack and mailbox auto-deletion tenant-wide. (Lin, today) 3. Stand up the privileged review team, directed by outside counsel. (Lin + Williams, day 2) 4. First scope call with FTC staff; ask for an extension of the return date in the same call. (Williams, by day 5) 5. Map specifications to systems and estimate volume and cost of a full production. (Lin + IT, day 5) 6. Pull the regulatory-notice clauses from the two Q3 renewal contracts. (Lin, day 5) 7. Prepare a three-sentence holding statement; do not use it unless asked. (Comms + Lin, day 7) Privilege & Hold. All review work is directed by outside counsel as work product. Any consultant or forensic vendor is retained through counsel, not by the company. Written analysis carries the privilege header. Nobody contacts the FTC except through Williams: no exceptions, including you. Comms & Disclosure. Internally: do not discuss the CID outside the privileged team. Externally: holding statement only, and only if asked. As a private company we have no securities disclosure obligation; that changes if we file an S-1 or if a Wells notice issues, and I will flag it the day it changes. Approvals Requested. 1. Engage outside FTC counsel, not to exceed $2.5M for sixty days. 2. Authorize a privileged internal review scoped to the data-feed product, 2022-present. 3. Approve the negotiate-scope posture. 4. Approve the hold scope and the single-channel comms protocol. --- *(For counsel, not for the meeting.)* Assumptions I made. That the theory is Section 5 deception rather than an unfairness or data-security theory. This is my read of specifications 3, 7, and 11, not something the CID states [verify with outside counsel]. That the return date is firm and extensions are routinely granted on first request [UNVERIFIED - confirm current staff practice]. That the two Q3 contracts contain regulatory-notice provisions [verify - pull the clauses]. Where this is weakest. The revenue-exposure paragraph assumes a consent order would force product changes that reach the whole data-feed line. That is the worst case, not the expected case, and a CFO will price it as if it were expected. Second: the posture table prices "resist" at $500K, which understates it badly if the FTC petitions to enforce. What only you can decide. Negotiate scope before producing anything: narrows the record and buys time, but the return date does not move on its own and staff may read delay as resistance, or produce the clean specifications on schedule while negotiating the hard three, which buys goodwill and shows good faith but concedes the frame and sets a production pace you have to sustain. Separately: open a full internal investigation now (you learn the facts before the agency does, and can self-correct while that still counts) or scope it to the specifications only (cheaper, generates less discoverable material, but you may end up briefing the CEO on facts the FTC found first). What would make this materially better. (1) The full text of specifications 3, 7, and 11: the theory paragraph is currently my inference. (2) The regulatory-notice clauses from the two Q3 renewals, which determine whether customers learn about this from us or from the press. (3) Whether anyone has already spoken to the FTC, formally or informally.

Why this prompt is built the way it is

## Framework 1. **Translate the vehicle first.** A CID, an administrative subpoena, a voluntary request, and a Wells notice are four different problems. Say which one this is, what happens if it is ignored, and whether it becomes public. 2. **Name the theory.** Read the specifications and say what the regulator suspects. "They think we told retailers one thing and consumers another" beats "the inquiry concerns our disclosure practices." 3. **Price it in business terms.** Revenue at risk, product changes a consent order would force, customer-contract triggers, follow-on private litigation, copycat state enforcement. 4. **Three postures, honestly drawn.** Cooperate fully, negotiate scope, resist. Each with approach, spend, timeline, and what it signals to the staff attorney who will remember it. 5. **Privilege and hold on day one.** Investigation directed by counsel, outside counsel engaged, hold issued, auto-deletion suspended, one channel for agency contact. 6. **Disclosure is a separate question.** Materiality, reporting obligations, and who decides. Prepare for a leak; do not volunteer. 7. **End in approvals.** Named, priced, and signable in the meeting, not "next steps."