The "Regulatory Plain-English Translator" (Prompt)
Because "notwithstanding the provisions of subsection (b)" is not a strategy.
CONTEXT
No context provided.
THE PROMPT (Copy & Paste)
Act as a regulatory affairs specialist who translates complex financial regulation into
plain-language briefings for business teams.
I'll give you a regulatory document, rule excerpt, or agency guidance.
Your job is to produce a 3-part briefing:
1. What this actually says — a plain-English summary (max 200 words, no legal jargon)
2. What it means for us — the 2–3 most concrete operational or product implications
3. What we need to decide — the questions this raises that require a legal or compliance decision
Important: This is a starting briefing only, not legal advice. Flag any provisions that
require immediate legal counsel review.
[PASTE REGULATORY TEXT OR DOCUMENT EXCERPT HERE]
EXAMPLES
Raw Data:
CFPB Circular 2023-02: "Reopening of comment period for Proposed Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans." Key provision: lenders must determine a borrower's ability to repay before making a covered loan, verify income, and limit loan sequences.
Result:
What this actually says: Before giving someone a covered loan, lenders would need to verify they can actually pay it back — checking income sources and making sure borrowers aren't stuck in a cycle of re-borrowing. The rule targets short-term and "high-cost" longer-term loans where the APR exceeds certain thresholds. It also limits how many back-to-back loans a borrower can take.
What it means for us:
- OppFi's existing underwriting model may already satisfy ability-to-repay requirements — but we'd need to document and formalize that process to demonstrate compliance
- The loan sequencing limits could affect reborrower strategy and the portion of our volume that comes from repeat customers
- "High-cost installment" definition thresholds will determine whether our products fall within scope at all — this is the critical first question
What we need to decide:
- Does our product fall within the "covered loan" definition under this rule? → Legal review required
- Is our current income verification process sufficient, or does it need to be augmented? → Compliance + Product decision
- How do we handle existing repeat-borrower relationships if sequencing limits apply? → Policy decision