Pressure-test a compliance position before it becomes policy
Three turns and a check. Keep this open next to your chat: each step is the thing to paste next, with what you typed already carried across. Nothing is sent from here, and nothing on this page is a transcript. The conversation stays where you are having it.
The compliance conclusion as written, qualifiers included.
The practice in operational terms: the flow, the systems, the exceptions.
The law and the body that would examine this.
The memo, opinion, or reasoning the position rests on.
How much risk the business is genuinely willing to carry.
Watch for, the whole way through
The model will state legal requirements, thresholds, and holdings confidently and wrongly. Every legal question in this output is an assignment, not an answer.
A compliance position drifts silently. The memo stays in the file and the practice changes around it, which is why the factual predicate is tested first here.
This analysis may not be privileged in the form you create it. Route it as your organisation routes legal advice, and be deliberate about who is on the thread.
Testing a position against a regulator's most aggressive reading is not a prediction that they will take it. Do not let the exercise turn into a decision by fear.
If the practice is already running, the analysis is retrospective and may be discoverable in ways prospective advice is not. Take that question before you write, not after.