You read a REGULATORY ISSUANCE PACKET -- one published issuance as a bank's regulatory change desk receives it -- together with the profile of ONE institution, and you return an APPLICABILITY WORKSHEET: does this issuance reach this institution, and which clause makes it so. You return JSON and nothing else.
You are preparing a worksheet for a regulatory-change analyst. You never open a change record, never assign an owner, never set a compliance date, never file anything, never waive anything and never clear an issuance as inapplicable. Your job is to say what the issuance's clauses state, apply the rulebook given below, and NAME THE DIMENSIONS THE ISSUANCE NEVER ADDRESSES.
RULES, in order of importance:
1. EXACTLY FOUR TEST ROWS, T1 T2 T3 T4, IN THAT ORDER, ON EVERY PACKET. T1 is CHARTER, T2 is ASSET SIZE, T3 is PRODUCT, T4 is ACTIVITY. A dimension the issuance never mentions is a row reading `not_addressed`, never an absent row: a worksheet that drops silent dimensions cannot be told apart from one that never checked them.
2. AN EXEMPTION INVERTS THE SENSE. A clause in an exemption or exclusion section, or phrased 'this part does not apply to', REMOVES an institution that meets its condition. So `criterion_met` on an exemption clause means the institution is OUT, and `criterion_not_met` on one means the institution stays IN. This is the branch a confident reader gets backwards.
3. FAILING TO QUALIFY FOR AN EXEMPTION IS NOT BEING OUT OF SCOPE. It is `exemption_not_available`, and it is the reason the issuance still bites. Never `out_of_scope`.
4. THE SUMMARY AND THE BACKGROUND DECIDE NOTHING. They name the subject in plain language and they name products and lines of business, and they are not clauses. Cite the clause that DECIDES -- in the scope section, the exemption section, or an operative paragraph of the substantive requirements. Never cite the Summary, the Background or the Distribution Notes.
5. `criterion_met` AND `criterion_not_met` ARE CLAIMS ABOUT THE INSTITUTION PROFILE BELOW, not about institutions in general. Check the clause's criterion against the profile's own charter type, its stated total consolidated assets, its list of products offered and its list of lines of business conducted.
6. `clause_kind` SAYS WHERE THE CRITERION IS STATED, and it is what makes rule 2 checkable. 'scope_clause' for the section that says who the issuance applies to; 'exemption_clause' for a section or clause that removes institutions; 'operative_paragraph' for a criterion stated inside a substantive requirement where no scope or exemption clause settles the dimension; 'none' only where the issuance says nothing on the dimension.
7. `test_call` IS DECIDED ONLY BY THE RULEBOOK BELOW, from `criterion_state` and `clause_kind`. Work through the six steps IN ORDER and STOP at the first that fires. In particular a criterion met inside an OPERATIVE PARAGRAPH is 'in_scope_by_operation' and never plain 'in_scope'.
8. `applicability` IS DECIDED ONLY BY THE RULEBOOK, from `instrument_type` and the four test calls. Decide it AFTER the four rows. An `interim_final_rule` is IN FORCE and is never 'monitor_only'.
9. 'not_addressed' IS A REAL ANSWER AND YOU ARE EXPECTED TO USE IT. Most issuances are silent on most dimensions. A dimension marked in scope on silence creates work nobody owes, and a dimension marked out of scope on silence closes an issuance that was never assessed.
10. Copy every reference verbatim from the packet -- the docket in `issuance_ref`, the clause reference in `clause_ref`. Use the exact allowed value for every field that lists them, and return every field for every row.
APPLICABILITY RULEBOOK (the authority for `test_call` and `applicability`; this is an ILLUSTRATIVE rulebook written for this kit, and it reproduces no statute, regulation, supervisory guidance or company procedure)
WHAT IS ON THE WORKSHEET
- EXACTLY FOUR TEST ROWS, T1 through T4, on every issuance. A dimension the issuance never mentions is a row reading `not_addressed`, never an absent row - a worksheet that drops silent dimensions cannot be distinguished from one that never checked them.
- ONE CLAUSE REFERENCE PER TEST, verbatim as the issuance prints it, and `none` when nothing addresses the dimension. A verdict with no clause behind it is an opinion.
- THE CLAUSE THAT DECIDES, NOT THE CLAUSE THAT MENTIONS. A summary paragraph that names a product is not the clause that decides whether the product is covered; the scope or exemption clause is. Where both exist, cite the deciding one.
- AN EXEMPTION IS READ IN ITS OWN SENSE. Meeting the condition of an exemption removes the institution. Failing to meet it leaves the institution in and is worth saying out loud.
- THE INSTRUMENT TYPE IS READ OFF THE ISSUANCE, NOT GUESSED FROM ITS TONE. A proposed rule reads exactly like a final one for pages at a time; the header and the comment period are what settle it.
THE FOUR TESTS
T1 CHARTER - the entity or charter type the issuance reaches
T2 ASSET SIZE - an asset-size criterion the issuance sets
T3 PRODUCT - a product or instrument the issuance covers
T4 ACTIVITY - a line of business or activity the issuance covers
INSTRUMENT TYPES
final_rule a rule adopted in final form, binding when its compliance date arrives
interim_final_rule a rule adopted and already in force while comment is still being taken. IT IS BINDING - the word interim describes the procedure, not the obligation
guidance a supervisory statement of expectation. Not a rule, and still an expectation the institution is examined against
proposed_rule a rule offered for comment. It imposes nothing yet
request_for_comment a request for views, with no text proposed for adoption. It imposes nothing yet
THE TWO STATED FACTS, read off the issuance for every test
criterion_state:
criterion_met the issuance states a criterion on this dimension and THIS institution meets it - the charter it names is this institution's charter, the asset threshold it sets is one this institution's assets satisfy, the product it covers is one this institution offers, the activity it covers is one this institution conducts
criterion_not_met the issuance states a criterion on this dimension and THIS institution does NOT meet it
not_addressed the issuance states no criterion on this dimension at all. It neither reaches this institution on it nor excludes it on it
clause_kind:
scope_clause the criterion is stated in a clause that says who the issuance applies to
exemption_clause the criterion is stated in a clause that REMOVES something from the issuance - an exemption, an exclusion, a carve-out or a safe harbour. The sense is inverted: meeting the condition of an exemption puts an institution OUT
operative_paragraph the criterion is stated inside a substantive requirement rather than in a scope or exemption clause. The paragraph says who must do the thing, and there is no general scope clause that settles it
none the issuance carries no clause on this dimension. This is the only value allowed when criterion_state is not_addressed, and the only criterion_state allowed with it
THE TEST CALL -- work through IN ORDER, stop at the first that fires
1. NOTHING SAID. If clause_kind is `none` or criterion_state is `not_addressed`, the worksheet records `not_addressed`. An issuance that never mentions a dimension neither reaches the institution on it nor excludes it on it, and an analyst who reads silence as either is inventing text.
2. THE EXEMPTION FIRES. If clause_kind is `exemption_clause` and criterion_state is `criterion_met`, the worksheet records `carved_out`. THE SENSE IS INVERTED HERE AND THIS IS THE BRANCH A CONFIDENT READER GETS BACKWARDS: an exemption whose condition the institution MEETS removes the institution, so a match on the words is the opposite of a match on the effect.
3. THE EXEMPTION IS THERE AND DOES NOT REACH. If clause_kind is `exemption_clause` and criterion_state is `criterion_not_met`, the worksheet records `exemption_not_available`. There was an off-ramp and this institution does not qualify for it. That is NOT the same as being out of scope - it is the reason the issuance still bites - and it is the row counsel most often wants to argue.
4. THE SCOPE DOES NOT REACH. If criterion_state is `criterion_not_met`, the worksheet records `out_of_scope`. The issuance states a criterion on this dimension and this institution does not meet it.
5. REACHED THROUGH AN OPERATIVE PARAGRAPH. If clause_kind is `operative_paragraph`, the worksheet records `in_scope_by_operation`. The criterion is met, and it is met inside a substantive requirement rather than in a scope clause - so a reviewer has to confirm the paragraph is one that binds this institution rather than describing a class it happens to fall in. Never plain `in_scope`: collapsing the two hides the hop somebody has to re-walk.
6. ANYTHING ELSE. The worksheet records `in_scope`.
THE APPLICABILITY CALL -- work through IN ORDER, stop at the first that fires
1. If any test call is `carved_out`, the worksheet records `excluded_by_exemption`. An exemption that fires ends the assessment; nothing further is owed on this issuance.
2. If any test call is `out_of_scope`, the worksheet records `does_not_apply`. A stated criterion this institution fails puts it out, whatever else the issuance reaches.
3. If instrument_type is `proposed_rule` or `request_for_comment`, the worksheet records `monitor_only`. The issuance would reach this institution and it imposes nothing yet. `interim_final_rule` is NOT in this branch - it is in force.
4. If no test call is `in_scope` or `in_scope_by_operation`, the worksheet records `indeterminate`. The issuance addresses none of the four dimensions in a way that reaches this institution, and it does not exclude it either. That is a finding about the text, not a gap in the assessment.
5. If no test call is `in_scope` - every positive one is `in_scope_by_operation` - the worksheet records `applies_subject_to_review`. Nothing in a scope clause puts this institution in; an operative paragraph does, and somebody has to read it.
6. ANYTHING ELSE. The worksheet records `applies`.
WHY `not_addressed` IS A REAL ANSWER
An applicability worksheet that never says `not_addressed` is not a thorough assessment, it is a confident one. Most issuances are silent on most dimensions, and the value of the worksheet is that an analyst can see, in one column, which dimensions the text actually settles and which ones somebody read into it. Over-confidence costs in both directions at once: a dimension marked in scope on silence creates work nobody owes, and a dimension marked out of scope on silence closes an issuance that was never assessed.
INSTITUTION PROFILE (the institution this assessment is for; every `criterion_met` in your reply is a claim about a fact on this list)
Profile id PROF-A
Institution Meridian Commercial Bank
Charter type federally chartered commercial bank
Deposit insurance insured
Holding company held by a registered bank holding company
Total consolidated assets $18.4 billion
Branches 212
Closed-end residential mortgage originations, in EACH of the two preceding calendar years 6200
PRODUCTS OFFERED
- residential mortgage lending
- residential mortgage servicing
- home equity lines of credit
- credit card issuing
- consumer deposit accounts
- commercial real estate lending
- small business lending
PRODUCTS NOT OFFERED
- agricultural lending
- trust and fiduciary services
- remittance transfers
- prepaid access products
- digital asset custody
- international correspondent banking
LINES OF BUSINESS CONDUCTED
- retail branch banking
- mortgage origination
- mortgage servicing
- card issuing
- commercial banking
- treasury management
LINES OF BUSINESS NOT CONDUCTED
- wealth and trust
- agricultural banking
- cross-border payments
- third-party sponsorship of fintech programs
THE FOUR LISTS ABOVE ARE EXHAUSTIVE. Every product and every line of business this assessment recognises appears on exactly one of them, so a criterion naming any of them is always either met or not met -- never unknown.
Return these:
- issuance_ref (string) -- the docket or issuance reference printed in the Issuance Header section, verbatim (for example ODS-2026-0114)
- instrument_type (enum) one of: final_rule, interim_final_rule, guidance, proposed_rule, request_for_comment -- what kind of instrument this is, read off the Issuance Header line 'Instrument:' and confirmed by whether a Comment Period section is present. 'interim_final_rule' is ALREADY IN FORCE -- the word interim describes the procedure, not the obligation -- and is never 'proposed_rule'
- scope_clause_ref (string) -- the reference of the FIRST NUMBERED CLAUSE in the issuance's scope or applicability section, verbatim as the issuance prints it (for example 'Section 2(a)'). Not the section's unnumbered preamble, and not a clause from any other section. Return the string 'none' when the issuance carries no scope or applicability section at all -- some issuances scope each requirement inside its own operative paragraph instead, and saying so is a real answer
- applicability (enum) one of: applies, applies_subject_to_review, does_not_apply, excluded_by_exemption, monitor_only, indeterminate -- the issuance-level call, decided STRICTLY by the shipped rulebook from `instrument_type` and the four test calls and nothing else -- so decide it AFTER the four test rows. IN ORDER, stopping at the first that fires. (1) any test call 'carved_out' -> 'excluded_by_exemption'. (2) any test call 'out_of_scope' -> 'does_not_apply'. (3) instrument_type 'proposed_rule' or 'request_for_comment' -> 'monitor_only' (NEVER for 'interim_final_rule', which is already in force). (4) no test call 'in_scope' or 'in_scope_by_operation' -> 'indeterminate'. (5) no test call 'in_scope' -> 'applies_subject_to_review'. (6) anything else -> 'applies'
- tests (array of exactly four objects, T1 T2 T3 T4 in order) -- each carrying:
- test_id (enum) one of: T1, T2, T3, T4 -- which applicability test this row is. THIS IS THE KEY -- return EXACTLY FOUR rows, one per test, in order: T1 CHARTER (the entity or charter type the issuance reaches), T2 ASSET SIZE (an asset-size criterion the issuance sets), T3 PRODUCT (a product or instrument the issuance covers), T4 ACTIVITY (a line of business or activity the issuance covers)
- criterion_state (enum) one of: criterion_met, criterion_not_met, not_addressed -- whether the issuance states a criterion on THIS dimension and whether THE INSTITUTION IN THE PROFILE BLOCK meets it. 'criterion_met' when it states one and this institution meets it; 'criterion_not_met' when it states one and this institution does not; 'not_addressed' when the issuance states no criterion on this dimension at all. Report what the criterion says and whether the profile matches it -- this is NOT on its own the applicability call, because an exemption inverts the sense
- clause_kind (enum) one of: scope_clause, exemption_clause, operative_paragraph, none -- WHERE the criterion is stated. 'scope_clause' when it is in a clause saying who the issuance applies to; 'exemption_clause' when it is in a clause that REMOVES something -- an exemption, exclusion, carve-out or safe harbour, usually phrased 'does not apply to' or 'is exempt from'; 'operative_paragraph' when it is stated inside a substantive requirement and no scope or exemption clause settles the dimension; 'none' when the issuance carries no clause on this dimension. 'none' is allowed only with criterion_state 'not_addressed', and 'not_addressed' is allowed only with 'none'
- clause_ref (string) -- the reference of the SINGLE clause that decides this test, verbatim as the issuance prints it (for example 'Section 2(c)(1)' or 'Section 4.3'). Cite the clause that DECIDES, not a summary paragraph that merely mentions the subject. Return the string 'none' when clause_kind is 'none'
- test_call (enum) one of: in_scope, in_scope_by_operation, out_of_scope, carved_out, exemption_not_available, not_addressed -- this test's worksheet call, decided STRICTLY by the shipped rulebook from `criterion_state` and `clause_kind` and nothing else. Work through the six steps IN ORDER, stopping at the first that fires. (1) clause_kind 'none' or criterion_state 'not_addressed' -> 'not_addressed'. (2) exemption_clause + criterion_met -> 'carved_out': AN EXEMPTION WHOSE CONDITION THE INSTITUTION MEETS REMOVES IT. (3) exemption_clause + criterion_not_met -> 'exemption_not_available'. (4) criterion_not_met -> 'out_of_scope'. (5) operative_paragraph -> 'in_scope_by_operation', never plain 'in_scope'. (6) anything else -> 'in_scope'
Return a JSON object with exactly these top-level keys: issuance_ref, instrument_type, scope_clause_ref, applicability, tests
`tests` is an array of EXACTLY FOUR objects, T1 T2 T3 T4 in that order. It is never shorter: a dimension the issuance does not address is a row reading `not_addressed`.
ISSUANCE PACKET
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Synthetic Record
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This is a SYNTHETIC regulatory-change packet generated by tools/build_corpus.py for the AI Foundry use-case kit `reg-applicability`. The issuing body, the docket reference, every section number, every sentence of the issuance and the institution it is routed to are INVENTED. Nothing here was copied from, adapted from or checked against any statute, regulation, register notice, supervisory letter, agency bulletin or bank procedure, because none was consulted. It describes no real institution, no real regulator and no real obligation, and it must never be treated as regulatory text.
Routing Slip
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Received by the regulatory change desk: 2026-01-03
Source feed: Federal Deposit Guarantee Board daily issuance feed
Routed to institution profile: PROF-A
Assessment owed: applicability, four tests, one worksheet
Issuance Header
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Issuing body: Federal Deposit Guarantee Board (FDGB)
Docket: FDGB-2026-0106
Instrument: Supervisory guidance
Published: 2026-01-03
Title: Prepaid access programme oversight
Summary
-------
The subject of this instrument is oversight of third-party programme managers. The Federal Deposit Guarantee Board has observed inconsistent practice across supervised institutions and sets out what it expects a record to contain, who must hold it and how long it must be kept. Institutions engaged in prepaid access products, and those whose credit card issuing operations touch the same records, have asked for clarity on the point.
THIS SUMMARY IS DESCRIPTIVE AND SETTLES NOTHING. Scope is settled by the Scope and Applicability Section below.
Scope and Applicability
-----------------------
This part applies to an institution that meets EVERY criterion stated in this Section. Where this Section states no criterion on a matter, that matter does not bear on whether this part applies.
Article II, paragraph 1 The institution is a federally chartered commercial bank or a federally chartered savings association.
Article II, paragraph 2 The institution has total consolidated assets of $3 billion or more, measured as of the most recent report of condition.
Exemptions and Exclusions
-------------------------
This Section removes institutions from this part. Where ANY paragraph of this Section reaches an institution, that institution is outside this part, whatever the scope clauses would otherwise require.
Article III, paragraph 1 This part does not apply to an institution that conducts agricultural banking.
Substantive Requirements
------------------------
Article V, paragraph 3 A record required by this part shall be retained in a form that permits retrieval within five business days of a supervisory request.
Article V, paragraph 4 An institution shall review the procedures adopted under this part at least annually and record the date of the review.
Article V, paragraph 5 An institution shall make a record required by this part available in a readable electronic form on request.
Article V, paragraph 6 An institution shall be able to identify the individual accountable for each record required by this part.
Article V, paragraph 7 Where a third party creates a record on an institution's behalf, the institution remains responsible for its contents and its availability.
Effective and Compliance Dates
------------------------------
Effective date: 2026-04-03.
Compliance date: 2026-04-03. An institution may adopt the practice earlier.
Distribution Notes
------------------
Circulated to the regulatory change desk and to the owners of the affected control library. Queries to the desk, not to the issuing body. Trade associations have signalled that they read this instrument as reaching every supervised institution; that reading is theirs and is not part of the issuance.