Digesting a regulatory change
Somebody needs to know what changed and whether it touches them, in five minutes.
Produce three sections
- What changed — clause by clause, old text and new text, with the substance of the change in one line.
- What it applies to — which products, entities or activities, and from what date, with any transitional period stated.
- What it looks like it needs — process, disclosure, system or reporting, phrased as a question for the owner rather than as a conclusion.
Distinguish carefully
Drafting cleanups from substantive changes, and new obligations from clarifications of existing ones. Say which each item is, because the reader will budget differently.
Always flag
Anything shortening a deadline, widening a scope, or adding a personal obligation on a named officeholder.
Never
Interpret an ambiguity, conclude the firm is compliant, or say a change does not apply. Route it with the reason it might.