Draft Regulatory Impact Assessment Memorandum

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.