# Extract Key Changes From Proposed Regulation > Agents extract the main proposed provisions and prepare a regulatory impact summary memorandum that evaluates operational effects, disclosure obligations, transaction-process implications, implementation burden, books-and-records considerations, and comment-period opportunities. - Skill: `finchipaiorg/extract-key-changes-from-proposed-regulation` (Agent Skill) - Install (CLI): `npx skillmds@latest add finchipaiorg/extract-key-changes-from-proposed-regulation` - Raw SKILL.md: https://api.skillmd.com/api/skills/finchipaiorg/extract-key-changes-from-proposed-regulation/raw - Safety review: pending - Works with: Claude Code, Claude.ai, OpenAI Codex - Category: Coding & Dev Tools - Author: FinchipAIOrg (https://skillmd.com/u/finchipaiorg) - Updated: 2026-09-22 - Page: https://skillmd.com/skills/finchipaiorg/extract-key-changes-from-proposed-regulation --- # Skill: Regulatory Impact Summary for a Proposed SEC Rule — Private Fund Adviser ## 1. Subject-matter triage - Identify the exact proposed SEC release, the affected adviser entity, and the current compliance baseline before evaluating impact. - If the source set includes more than one fund, strategy, or operating model, enumerate each one first and assess them separately rather than assuming a single representative structure. - Flag at the outset whether the memo is a pure gap analysis, a gap analysis with implementation roadmap, or a comment-letter precursor; do not blur those functions. ## 2. Failure modes the skill is correcting - Summarizing the proposal’s headline items without mapping each change to the firm’s current procedures, disclosures, records, and governance controls. - Missing how fee, expense, and performance disclosure changes affect existing quarterly statement and investor-reporting workflows. - Overlooking transaction-process changes in adviser-led or continuation-style secondary transactions, including the need for independent opinions and the effect of advisor conflicts. - Treating side letters and preferential terms as a generic disclosure issue rather than testing them against the proposal’s specific restrictions and exceptions. - Failing to connect expanded books-and-records duties to the firm’s retention, audit trail, and evidentiary support practices. - Listing issues without assigning severity, operational burden, or a concrete implementation path. - Describing the rule but not the controlling SEC authority that supports the compliance conclusion. - Missing the comment-period opportunity to shape calibration where the proposal does not fit the firm’s fund structures. ## 3. Legal frameworks / domain conventions that apply - Anchor the analysis in the operative Advisers Act framework and the proposed SEC release governing private fund advisers. - Treat quarterly statement requirements as a disclosure-and-calculation regime: fees, expenses, performance, and methodology must be tested against how the firm actually compiles and presents investor reporting. - Treat transaction-related opinion requirements as a conflict-management and independence issue; the analysis must test whether current advisor relationships would satisfy the proposal’s independence standard. - Treat preferential treatment provisions as a side-letter and investor-parity issue; identify whether material economic terms, liquidity preferences, information rights, or other special arrangements require disclosure or are constrained. - Treat books-and-records expansion as a retention and substantiation issue; the firm must be able to recreate the basis for statements, opinions, and restricted-activity judgments. - Treat comment-period analysis as a legal-strategy step, not an afterthought; identify the provisions that are most vulnerable to overbreadth, operational mismatch, or unintended consequences for the client’s structure. - Cite the controlling authority for each proposition relied upon, using the statute, rule, release, or other recognized authority that governs the point. ## 4. Analytical scaffolds - Use a provision-by-provision comparison: proposed requirement, current practice, compliance gap, implementation burden, and recommended action. - For each provision, test three questions in order: what changes in law or SEC position are being proposed, what is the firm doing today, and what must change operationally if the proposal is adopted. - Where the proposal turns on independence, evaluate the relevant counterparties, service providers, and recurring relationships against the stated standard before drawing a conclusion. - Where the proposal turns on disclosure, separate investor-facing content, internal data sources, and calculation methodology so the memo distinguishes drafting work from systems work. - Where the proposal turns on transaction process, identify the decision points that would need new approvals, notices, or third-party deliverables. - Where the proposal turns on records, identify the documents that must be created or retained, who owns them, and where the existing process would fail. - Assign an ordinal severity to each gap and define the scale once near the top of the memo so the reader can distinguish critical implementation blockers from lower-risk refinements. - Close each identified gap with: the relevant scale or scope, the interaction with another requirement or process, and the downstream consequence for the adviser. - Build the implementation timeline from the proposal’s effective-date logic and operational lead times, then sequence work by dependency rather than by topic alone. - End with a concrete recommendations block that names the actor responsible and the timing anchor for each action. ## 5. Vertical / structural / temporal relationships - Compare the proposed rule to the current compliance framework at the level of workflow, not just policy text. - Distinguish obligations that apply at point of transaction, at periodic reporting intervals, at onboarding, and at retention/post-close stages. - If the firm uses different funds or sleeves with different fee logic, side-letter practice, or transaction approval paths, separate them vertically rather than collapsing them into one generalized answer. - When a provision affects multiple internal teams, map the relationship between legal, compliance, finance, operations, investor relations, and portfolio management so the memo shows who must move first. - Where timing matters, identify immediate remediation, pre-effective-date buildout, and post-effective-date monitoring as distinct phases. ## 6. Output structure conventions - Prepare a regulatory impact memorandum in conventional memo form with a short executive summary, a rule-by-rule gap analysis, an implementation timeline, and a closing recommendations section. - Include a summary table that pairs each major proposed provision with current status, gap description, severity, required action, owner, and target timing. - For each substantive provision, state: the proposed requirement, the firm’s current position, the compliance gap, the operational effect, and the recommended fix. - Include a separate section for comment-period strategy when the proposal is still open for comment or when prior comment history makes further advocacy useful. - Use plain-text labels that survive conversion and make the memo usable in Word without relying on visual formatting alone. - If the analysis references a legal conclusion, tie it to the controlling authority in the same paragraph or row. - Conclude with an explicit Recommended Actions block naming the responsible role and a timing anchor for each item.