Regulatory Cold-Start Interview

Regulatory Cold-Start Interview

Purpose

Conduct a structured, staged interview with a regulatory practice group — led by a supervising attorney or authorized designee — to gather the information required to populate practice-profiles/regulatory.md. The skill walks through all eight profile fields in sequence, records every answer, and assembles a filled draft of the profile for the practice group's review and approval. It produces draft legal work product for attorney review — not legal advice and not a final configuration.

Use When

• A team is adopting AgentCounsel and needs to configure practice-profiles/regulatory.md for the first time.
• A regulatory practice group is being onboarded to the library and no current profile exists.
• The library is being stood up for the first time and the regulatory area is included in scope.
• A practice group wishes to revisit or rebuild its profile from scratch rather than make incremental updates.

Required Inputs

• A knowledgeable person from the regulatory practice group — a supervising attorney or an authorized designee — who can answer questions about the group's jurisdiction, positions, escalation rules, and review requirements.
• Any existing playbooks, templates, source-of-truth documents, or standard-form documents the group already uses, so they can be referenced or cited in the profile.

Do Not Use When

• The group is actively working a live regulatory matter. This skill configures the library; it does not support an open matter.
• A practice-profiles/regulatory.md already exists and is current. In that case this is a refresh, not a cold start — though the skill may still be used to rebuild the profile deliberately.
• No authorized person is available to answer. Do not complete the interview with guessed or inferred answers; record all gaps as [CONFIRM: ...] placeholders.
• The purpose is to handle a specific regulatory matter (use the appropriate matter-level skill for that task).

Legal Safety Rules

• Produce draft legal work product for attorney review. This is not legal advice.
• Never guess or infer an answer to any interview question. If the interviewee cannot answer a question, record [CONFIRM: answer required from practice group] and move on.
• The filled profile is a draft. It must be reviewed and explicitly approved by the supervising attorney or practice group before it governs any AgentCounsel work product.
• Do not invent standard positions, clause preferences, escalation thresholds, or review rules. Record only what the interviewee provides.
• Do not include client-specific facts, client names, matter identifiers, or privileged details in the profile. The profile is a reusable group-level configuration, not a matter record.
• Do not state or imply that any threshold, position, or rule in the profile satisfies a legal requirement under any jurisdiction. Jurisdiction-specific legal obligations are for the attorney to verify.
• Flag every item the interviewee defers or leaves open with a visible [CONFIRM: ...] placeholder so the reviewer can see exactly what is unresolved.

Workflow

Stage 1 — Jurisdictions

Ask the interviewee:

• In which jurisdictions and before which agencies does the group regularly practice — US federal agencies (which ones), US state agencies, foreign regulators, multi-jurisdictional matters?
• What sectors does the group regularly engage with — energy, telecom, healthcare, financial services, transportation, environment, consumer protection?
• Are there sectors or agencies the group treats as out of scope, requiring specialist outside counsel?
• Does the group maintain agency-specific or sector-specific reference materials, and where are they stored?
• Does the group track foreign regulatory developments that affect US clients (e.g., EU regulatory parallels)?

Record answers. Mark any unanswered item [CONFIRM: jurisdiction not yet specified].

Stage 2 — Client and Team Context

Ask the interviewee:

• Does the group represent primarily regulated entities, complainants, intervenors, or a mix?
• What types of regulatory matters does the group handle most frequently — advisory, rulemaking participation, license / permit, enforcement defense, agency engagement?
• How is the team structured — sector specialists, generalist regulatory counsel, paralegals, consultant relationships?
• How does the group coordinate with sector technical experts, government-affairs counsel, lobbyists, and trade associations?
• Are there client categories — public-utility holding companies, hospitals, banks, broker-dealers — that require special handling?

Record answers. Mark any unanswered item [CONFIRM: client/team context not yet specified].

Stage 3 — Escalation Thresholds

Ask the interviewee:

• Which matters automatically require escalation — regulatory inquiry, subpoena / CID, sanctions risk, license / permit revocation, rulemaking participation above threshold?
• Are there sector-specific scenarios — bank examiner inquiry, FDA warning letter, FTC investigative demand — that require immediate review?
• When does an agency engagement (informal meeting, settlement discussion, consent decree negotiation) require partner-level involvement?
• Which rulemaking matters (notice-and-comment, hearing participation, ex parte) require attorney review regardless of size?
• Who is the designated escalation contact for regulatory matters, and what is the expected turnaround?

Record answers. Mark any unanswered item [CONFIRM: escalation threshold not yet specified].

Stage 4 — Preferred Output Style

Ask the interviewee:

• Should regulatory work product default to memo format, agency-letter format, comment-letter format, or compliance-checklist format?
• What level of detail does the practice group expect — executive summary, full reasoning with agency-precedent citations, both layered?
• Are there house style rules for citation format (agency decisions, no-action letters, guidance documents), risk ratings, or open-items lists?
• Does the group produce rulemaking-comment letters or compliance-program review memos in standard formats?
• Are there particular deliverable types — agency responses, comment letters, enforcement-defense memos — for which the group has mandatory format requirements?

Record answers. Mark any unanswered item [CONFIRM: output style preference not yet specified].

Stage 5 — Source-of-Truth Documents

Ask the interviewee:

• What is the group's authoritative library of agency-precedent references, and where is it stored?
• Is there a regulatory-tracking system (rulemaking docket, enforcement actions, agency-guidance changes), and how is it kept current?
• What document governs the group's comment-letter framework?
• Are there compliance-program-review templates or audit-checklist templates the group treats as authoritative?
• Does the group maintain agency-specific protocols for informal contacts, voluntary disclosures, and settlement engagement?

Record answers and document names. Mark any unanswered item [CONFIRM: source document not yet identified].

Stage 6 — Standard Positions and Playbooks

Ask the interviewee:

• What is the group's default regulatory engagement posture — proactive engagement, reactive engagement, situational?
• What is the group's default rulemaking-participation threshold — what types of rulemakings warrant a comment letter, and what types warrant a presence at hearings?
• What is the group's default approach to voluntary disclosures — when warranted, what scope?
• What is the group's default comment-letter framework — issue spotting, position taking, both?
• What is the group's default compliance-program-review posture for new regulatory regimes?

Record answers. Mark any unanswered item [CONFIRM: standard position not yet specified].

Stage 7 — Attorney Review Requirements

Ask the interviewee:

• At what stage does attorney review of regulatory work product become mandatory — initial intake, draft comment letter, draft agency response, draft compliance-program update?
• Are there work-product types for which attorney review is always required regardless of size — any agency filing, any rulemaking comment, any voluntary disclosure, any consent-decree negotiation?
• What is the designated reviewer's role — handling attorney, supervising sector partner, regulatory specialist?
• What is the expected turnaround for regulatory review, and how are urgent reviews (agency-deadline-driven, enforcement matters) handled?
• Is there a formal sign-off step before any agency submission or rulemaking comment is filed?

Record answers. Mark any unanswered item [CONFIRM: review requirement not yet specified].

Stage 8 — Prohibited Assumptions

Ask the interviewee:

• Are there facts agents must never assume without explicit confirmation — that a regulation is current, that an interpretation is binding, that an exemption applies, that an enforcement action is unlikely, that an agency precedent is on point?
• Are there regulatory risks — investigation, enforcement, license-revocation, criminal referral — where an agent must stop and escalate rather than reason through independently?
• Are there matter types where agents must never proceed beyond intake without direct attorney involvement — agency investigations, consent-decree matters, enforcement defense?
• Are there prior incidents — adverse enforcement actions, consent decrees, regulatory findings — that should be encoded as explicit prohibitions for agents working on regulatory matters?

Record answers. Mark any unanswered item [CONFIRM: prohibited assumption not yet specified].

Stage 9 — Assemble the Draft Profile

Compile all answers into a filled draft of practice-profiles/regulatory.md, populating each of the eight profile sections. For every item that was not answered, insert a visible [CONFIRM: ...] placeholder with enough context for the reviewer to understand what needs to be supplied. Append a list of all open placeholders so the reviewing attorney can see at a glance what remains unresolved.

Output Format

Deliver:

1. Filled draft of practice-profiles/regulatory.md — all eight sections populated with answers from the interview. Every unanswered item is a visible [CONFIRM: ...] placeholder.
2. Open-items list — an explicit enumeration of every placeholder inserted, with the stage and question it corresponds to, so the reviewing attorney can resolve them efficiently.

Label the entire output: Draft legal work product for attorney review. Not legal advice. This profile draft must be reviewed and approved by the supervising attorney or practice group before it is relied upon.

Attorney Verification Checklist

• All eight profile sections have been reviewed by a supervising attorney or authorized practice-group representative.
• Agency / jurisdiction coverage and sector specialization are accurately recorded.
• Regulatory-tracking system reference is current and maintenance owner is named.
• Voluntary-disclosure framework and rulemaking-participation thresholds reflect the group's current considered posture.
• Agency deadlines (comment periods, response windows, hearing dates) are marked [deadline verification required] in any related deliverable.
• Current-law verification is required for any analysis that turns on a regulation, agency interpretation, or guidance document [Verify current law].
• No client-specific facts, matter identifiers, or privileged details appear in the profile.
• All [CONFIRM: ...] placeholders have been resolved or explicitly accepted as pending.
• The approved profile has been saved to practice-profiles/regulatory.md and its effective date recorded.
• A process for periodic profile review and update has been identified.