policy-gap-analysis

Scope

Do: compare specific regulation sections to a firm policy clause by clause, quote both sides, assign coverage states, suggest owner-reviewed edits Do not: conclude compliant, non-compliant, or in violation, score unretrieved requirements, treat drafts or unretrieved referenced documents as coverage, alter source systems, send, or file anything

When NOT to Use

• Triaging a newly published rule across the firm — use reg-change-triage instead.
• An examiner request list or PDL response tracker — use exam-request-response instead.
• Formatting, charting, or restyling an existing workbook — use xlsx instead.

Policy-to-Regulation Gap Analysis

Clause-by-clause: what the regulation requires, what the policy says, and whether the second addresses the first.

This skill never concludes compliance. It reports coverage states with both sides quoted. Whether the firm complies is a determination by a qualified owner — house-rules.md § 2.

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Read first

Read these in full before step 1. They are binding; this body only summarises them.

• references/workflow.md — the full text of every step below, with the guardrails, source resolution, and footer detail.
• references/house-rules.md — destination gate, determination gate, authority tiers, markers, footers, and § 12 data minimisation (every artifact, search, and chat reply, declines included).
• references/reg-source-access.md — routing, the codification gap, precision filtering.
• references/document-extraction.md — policy version and approval discipline.
• references/gap-outline.md — default table and memo structure: the output format.
• references/self-check.md — the final self-check (step 7).

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Workflow

1. Establish both sides before comparing

Detail: workflow.md § 1.

• Regulation: agency · citation · type · tier · sections in scope. Retrieve per reg-source-access.md and run the codification check; an effective later final rule governs (PENDING CODIFICATION), a future one is a forthcoming change in the Source cell. House-rules markers only, plus PROPOSED DRAFTING.
• Policy: name · version · approval status · approval date · owner · scope. A draft is DRAFT — not approved, never the control of record. When the policy given is a draft or superseded, find and open the approved version and state Control of record: <doc> v<x>, approved <date> (<location>) in § 2 and the chat reply: a fact, never a D-bullet. Version or approval unknown → GAP — policy version not established, and no row is scored as covered.
• Scope is load-bearing. Quote the policy's scope clause. Which entities, accounts, or products the rule covers is proposed applicability: NOT DETERMINED, compliance owner decides, with the retrieved defining provision cited. If that provision was not retrieved, the reasoning reads exactly none - defining provision not retrieved. No hedge words.