--- description: Audit a workflow or business process against insurance, mortgage, or financial services regulatory requirements. Use when a client workflow needs regulatory sign-off or when validating that a proposed automation meets compliance requirements before build. model: sonnet allowed-tools: - Read - Grep - Bash --- # Compliance Check Perform a structured regulatory compliance audit of a workflow or business process against applicable insurance, mortgage, or financial services requirements. ## Step 1: Identify Applicable Regulations Determine which regulatory frameworks apply based on entity type, product lines, and states of operation. **Insurance:** - State Department of Insurance rules for each state of operation (admitted vs. surplus lines) - NAIC model laws (Market Conduct, Privacy, Claims Settlement Practices) - Producer licensing requirements (lines of authority, CE, non-resident) **Mortgage:** - TRID (TILA-RESPA Integrated Disclosure) — Reg Z/X - RESPA Section 8 (kickback/fee-splitting prohibition) - HMDA/Regulation C (data collection and reporting) - QM/ATR (Qualified Mortgage / Ability to Repay — Dodd-Frank) - ECOA/Regulation B (fair lending, adverse action) - FCRA (credit report permissible purpose, adverse action notices) **Financial Services:** - FINRA rules (broker-dealer supervision, suitability, recordkeeping) - SEC regulations (investment advisor registration, fiduciary duty) - BSA/AML (Bank Secrecy Act, Anti-Money Laundering — suspicious activity reporting, CIP) - State money transmitter laws (if applicable) ## Step 2: Map Requirements to Workflow Steps For each identified regulation, trace its requirements to specific steps in the workflow: | Regulation | Requirement | Applicable Workflow Step | Responsible Role | |------------|-------------|--------------------------|-----------------| | [Reg] | [What must happen] | [Step name/number] | [Who] | Flag each workflow step that touches a regulated activity. Mark steps with no regulatory mapping as low-risk baseline. ## Step 3: Gap Analysis For each requirement-to-step mapping, assess whether the current workflow design satisfies the requirement: - **Compliant**: Workflow step explicitly addresses the requirement with documented evidence - **Partial**: Requirement is partially addressed; specific gaps identified - **Non-Compliant**: Requirement is not addressed in the current design - **Not Applicable**: Requirement does not apply to this specific workflow variant **Severity classification for gaps:** - **Critical**: Non-compliance exposes client to regulatory enforcement, license revocation, or civil liability - **High**: Non-compliance is likely to be cited in an examination or audit - **Medium**: Non-compliance may be cited; remediation is straightforward - **Low**: Best practice not followed; unlikely to be cited but should be addressed ## Step 4: Remediation Backlog For each gap, produce a remediation item: ``` GAP-[N]: [Short title] Regulation: [Specific statute/rule citation] Severity: Critical | High | Medium | Low Current state: [What the workflow does today] Required state: [What it must do] Remediation: [Specific change required — be actionable] Complexity: Low (< 1 day) | Medium (1–3 days) | High (3+ days) Owner: [Role responsible] ``` ## Step 5: Sign-Off Evidence Checklist List the documentation a compliance officer or regulator would need to confirm each requirement is met: - Policy/procedure documents that address each requirement - Training records for staff who execute regulated workflow steps - Audit log evidence that required fields are captured - Sample outputs (disclosures, notices, reports) showing required content - System screenshots or configuration exports showing controls are active - Testing evidence (QA sign-off, UAT sign-off) for compliance-critical steps ## Output Format Produce a **Compliance Review Report** with these sections: 1. **Executive Summary** — Entity type, product lines, states reviewed; overall compliance posture (Compliant / Partially Compliant / Non-Compliant); count of Critical/High/Medium/Low gaps 2. **Regulatory Universe** — Table of all applicable regulations with brief description and applicability rationale 3. **Requirement-to-Workflow Mapping** — Full mapping table from Step 2 4. **Gap Analysis** — Findings table with severity, current state, required state 5. **Remediation Backlog** — Prioritized list from Step 4 (Critical first) 6. **Sign-Off Evidence Checklist** — Documentation required for each requirement 7. **Open Questions** — Items requiring client clarification before the review can be finalized