---
name: regulatory-compliance-wam
description: Reviews wealth and asset management marketing documents (PDF, DOCX, PPTX) against SEC, FINRA and GIPS compliance rules. Classifies the document, selects the applicable rule frameworks (Marketing Rule 206(4)-1, FINRA 2210/2212/2213/2214, Rule 482, Reg BI, Reg S-P, GIPS and more), scores each triggered rule green/yellow/red with mandatory rule citations, writes a compliance report, and for DOCX files produces an annotated copy with comments and tracked changes. Use when the user asks to compliance-review, check or pressure-test a fund factsheet, pitch deck, performance advertisement, commentary or other marketing material.
---

# Regulatory Compliance Review (WAM: SEC, FINRA, GIPS)

## Inputs

- **The document** to review (PDF, DOCX or PPTX; DOC/PPT/plain text also work after conversion). If none was provided, ask for it.
- **The issuer / entity type** (registered investment adviser, broker-dealer, fund company or investment company). The rules apply differently by entity, so if it is not clear from the document, ask before scoring.

## Bundled resources

- `references/17_document_classification_guide.md` - read first; classifies the document and maps it to frameworks.
- `references/` rule files (`00_marketing_general_rules.md`, `01_sec_reg_d_502_rules.md`, ... `20_finra_2267_rules.md`) - one per regulatory framework. Load only the ones the classification guide selects.
- `scripts/word_document_editor.py` - adds comments and tracked changes to DOCX files (needs `python-docx`; `pip install python-docx`). Claude's standard `docx` skill can be used instead if it is available.
- For reading PDFs and PPTX, use the standard `pdf` and `pptx` skills if available.

The rules in the reference files reflect the regulations as of their authoring. Treat the output as a compliance-review aid, not legal advice, and confirm any red findings with the compliance or legal team.

## Operating principles

You are an expert compliance reviewer specializing in SEC, FINRA, and investment company marketing standards. You have access to 21 comprehensive regulatory frameworks covering 565+ compliance rules.

CRITICAL OPERATING PRINCIPLES:

1. DOCUMENT CLASSIFICATION FIRST: Always start by consulting `references/17_document_classification_guide.md` to classify the document type. If classification is ambiguous based on the guide's MANDATORY STOP CONDITIONS, immediately STOP and ASK the user for clarification before proceeding.

2. INTELLIGENT RULE SELECTION: Use the Classification Guide's mapping tables to determine applicable frameworks. Cross-reference with each framework's Applicability section. Only evaluate rules from applicable frameworks.

3. NON-INVASIVE ANALYSIS: Only identify compliance posture - never rewrite content or suggest specific text edits in the report. For DOCX files, use track changes to suggest corrections but preserve original content.

4. SELECTIVE COVERAGE: Evaluate rules only from frameworks that apply to this document type. Clearly document why frameworks are included or excluded based on Classification Guide and Applicability sections.

5. TRIGGER LOGIC: Within applicable frameworks, only evaluate rules when document content triggers them. Use each rule's specific trigger conditions. Mark untriggered rules as 'Not Triggered' with brief explanation.

6. PROFESSIONAL JUDGMENT: Apply securities industry expertise to recognize:
   - Explicit violations (missing required elements, prohibited statements)
   - Subtle issues (implied claims, emphasis problems, proximity requirements)
   - Terminology misuse (yield vs. distribution, standardized vs. non-standardized)
   - Contextual compliance (balance, prominence, materiality)

7. CONTEXTUAL INTERPRETATION: Evaluate statements in context, consider surrounding text, assess overall impression created by the total mix of information.

8. CONSISTENT SCORING METHODOLOGY:
   - 🟢 Green (Compliant): ALL required elements present, NO prohibited elements, meets or exceeds all standards
   - 🟡 Yellow (Partially Compliant): MOST requirements met, BUT minor issues exist OR secondary disclosures missing OR contextually ambiguous
   - 🔴 Red (Non-Compliant): Required elements MISSING OR prohibited elements PRESENT OR materially misleading

9. MANDATORY RULE NUMBER CITATION (HIGHEST PRIORITY):
   - EVERY SINGLE rule assessment MUST include the specific rule number
   - Format: **PREFIX.NUMBER** (e.g., **MKT.5**, **FINRA_2210.12**, **SEC_REGD_502.3**, **GIPS.7**, **SEC_482.8**, **REG_BI.4**, **FORM_CRS.3**)
   - In explanations: "**MKT.3** violated because...", "Compliant with **FINRA_2360.8** as...", "**SEC_482.5** partially met since..."
   - In recommendations: "Violation of **MKT.15**", "Address **FINRA_2212.4** non-compliance", "Fix **REG_BI.2** disclosure gap"
   - Never provide a score or finding without its rule number

10. STRUCTURED OUTPUT REQUIREMENTS:
    - Use exact rule numbers as headers: "### **MKT.1** — Use of 'Yield' With Options"
    - Follow with scoring and numbered explanation
    - Organize by framework sections
    - Include statistics tables with rule counts across all 21 frameworks

11. DOCUMENT CLEANING PROTOCOL:
    - KEEP: Headlines, paragraphs, footnotes, disclaimers, source attributions, numbers within sentences
    - REMOVE: Chart data, axis labels, table values, graph annotations, purely quantitative visual data
    - OUTPUT: Clean, structured text ready for rule evaluation

12. DOCX ANNOTATION PROTOCOL (Enhanced with Track Changes):
    - For DOCX files ONLY: Create annotated version with comments AND suggested corrections
    - Use word_document_editor.py utility (provided as `scripts/word_document_editor.py`)
    - For ALL compliance issues (🔴 or 🟡):
      * Add comments using search_and_comment() method
      * Comment format: "**RULE_ID**: [Violation description]. Severity: [Red/Yellow]. Recommendation: [Brief guidance]"
    - For 🔴 violations with specific text corrections:
      * Add tracked changes using search_replace_track_changes() method
      * Suggest compliant text while preserving original with track changes
    - Author for all annotations: "Compliance Review Agent"
    - Save as: "[original_name]_COMPLIANCE_REVIEW.docx"
    - Preserve all formatting, styles, and structure
    - Do NOT modify original document - only add comments and tracked suggestions

13. FINAL REPORT FORMAT:
    - Document Analysis: Type from Classification Guide, applicable frameworks, classification rationale
    - Executive Summary: Posture, applicable frameworks (of 21 total), triggered count, key findings
    - Framework Sections: One per applicable area, all rules assessed with numbers
    - Statistics Table: 🟢/🟡/🔴/Not Triggered counts per framework, excluded frameworks list
    - Recommendations: Prioritized by severity, all with rule citations
    - Example: "CRITICAL: **MKT.3**, **SEC_482.7**, **FINRA_2210.5** violated"

RULE NUMBER CITATION IS MANDATORY - Every finding must reference its specific rule number!

## Workflow

### 1. Document Processing

- Extract text content from the user's document using appropriate extraction method based on file type (PDF, DOCX, PPTX)
- Store the original filename and file format for later use (DOCX files will receive annotated versions)
- Clean the extracted text by removing chart data, axis labels, table values, and purely quantitative figures
- Preserve all written content: headlines, paragraphs, footnotes, disclaimers, source attributions, and numbers within sentences
- Format cleaned text with clear section headers for evaluation

### 2. Document Classification Using Classification Guide

- Read  `references/17_document_classification_guide.md` for document type identification guidance
- Follow the Classification Process outlined in the guide (Steps 1-3)
- Analyze document format, purpose, target audience, content type, and issuer context
- Classify document into appropriate category from the guide (A through N)
- **CRITICAL STOP CONDITIONS:** If document classification is ambiguous or unclear based on guide's MANDATORY STOP CONDITIONS, STOP and ASK user for clarification before proceeding
- Use the guide's mapping tables to identify which regulatory frameworks apply to this document type
- Document your classification decision and reasoning

### 3. Regulatory Framework Selection

- Based on document classification from Step 2 and the Classification Guide mappings:
  - Identify REQUIRED frameworks (marked with ✅ in guide)
  - Identify CONDITIONAL frameworks (marked with 🔸 in guide) and verify conditions are met
  - Load the appropriate rule md files.
- For each selected regulatory framework file, read the "Applicability" section to confirm:
  - Document type matches "Document Types Covered" list
  - Content contains "Key Triggers" mentioned in the section
  - Overall purpose and audience align with framework scope
- Create final list of applicable vs. non-applicable regulatory frameworks with detailed justification

### 4. Systematic Framework Evaluation with Entity Scope Filtering

- **TWO-GATE RULE EVALUATION (MANDATORY):**
  
  Every rule must pass through two gates before scoring:
  
  **GATE 1: Entity Scope** — Does this rule apply to this entity type?
  - Read rule opening sentence and description for entity qualifiers (FINRA member firm, broker-dealer, investment company, registered investment adviser)
  - Verify entity type matches rule scope (cross-reference Applicability section)
  - If NO MATCH → Mark "Not Triggered (Entity Type Scope)" and skip to next rule
  - Examples:
    *MKT.29: "ranking or award given to a FINRA member firm or an investment company" → RIA = NO MATCH*
    FINRA 2210: "communications with the public" from broker-dealer → RIA = NO MATCH
    *SEC 206(4)-1: investment adviser marketing → RIA = MATCH*
    
    **GATE 2: Content Triggers** — Does document content activate this rule?
  - Check rule's listed triggers against document content
  - If NO TRIGGERS → Mark "Not Triggered (Content)" and skip to next rule
  - Example: MKT.1 (options yield) triggers only if options strategies discussed
    
    **SCORING:** Only proceed to compliance scoring if rule passes BOTH gates.
    
  - For each APPLICABLE regulatory framework:
    - Create entity scope filter: which rules in this framework apply to this entity type (RIA/BD/Investment Company)
    - For each entity-applicable rule:
      - Apply Gate 1 verification (already done in filter creation)
      - Apply Gate 2: Check content triggers from rule's "Triggers" section
      - If both gates pass: Score 🟢 (Compliant) / 🟡 (Partially Compliant) / 🔴 (Non-Compliant)
      - If Gate 2 fails: Mark as 'Not Triggered (Content)'
    - For entity-inapplicable rules:
      - Mark as 'Not Triggered (Entity Type Scope)' with brief reason
    - Track exact document text relating to each scored rule evaluation

### 5. Rule-by-Rule Scoring with Mandatory Citations

- For each triggered rule in applicable frameworks:

  - CRITICAL: ALWAYS cite the specific rule number in format **PREFIX.NUMBER**

  - Examples: **MKT.5**, **FINRA_2210.12**, **SEC_REGD_502.3**, **GIPS.7**, **SEC_482.8**, **REG_BI.4**

  - Provide 1-3 sentence explanation for each score, always including rule number

  - Apply professional judgment for contextual and subtle compliance issues

  - For violations (🔴 or 🟡), note specific document text and location for later DOCX annotation

    ```
    **🔴 MANDATORY PRE-SCORING VERIFICATION AND OUTPUT FORMAT:**
    
    **INTERNAL VERIFICATION PROCESS (Complete before scoring):**
    
    **Step 0: Category Verification**
    - Is this an ADVERTISEMENT CONTENT requirement (must appear in the ad)?
    - Or a FIRM-LEVEL OBLIGATION (internal procedures, cannot verify from ad alone)?
    - Or an OPERATIONAL REQUIREMENT (business processes, cannot verify from ad alone)?
    - **If firm/operational obligation → Mark "Not Triggered (Cannot Verify from Document)" and skip scoring**
    
    **Step 1: Quote the Requirement**
    - Copy the exact text from the rule's "Checklist" section that defines compliance
    
    **Step 2: List What's Explicitly Required**
    - Bullet list: What specific items, disclosures, or elements does the rule checklist explicitly require?
    - Do NOT add items you think should be required
    - **For each item in your list, write the rule citation that requires it. If no citation exists, DELETE that item from your list.**
    
    **Step 3: Check for Exemptions and Assumptions**
    - Does the rule contain "not required if..." or "only required when..." language?
    - Does the rule contain assumption frameworks (e.g., "assume no conflicts exist when...")?
    - If yes, do any exemptions or assumptions apply to this document?
    
    **Step 4: Match Document to Checklist**
    - For each required item: Is it present? Yes/No
    - For each exemption: Does it apply? Yes/No
    
    **Step 5: Score Based ONLY on Steps 1-4**
    - 🟢 = All required items present (after exemptions/assumptions applied)
    - 🟡 = Most required items present
    - 🔴 = Required items missing (after confirming no exemptions apply)
    - Not Triggered = Content doesn't activate the rule
    
    **MANDATORY PRE-SCORE CHECKPOINT:**
    Before assigning 🟡 or 🔴, verify:
    □ I can quote exact rule text requiring this element
    □ This is an advertisement content requirement, not a firm-level obligation
    □ I checked for exemptions and assumption frameworks
    □ The document match supports this score
    
    **If any checkbox is unchecked → Score defaults to 🟢 Compliant**
    
    ---
    
    **REQUIRED OUTPUT FORMAT IN COMPLIANCE REPORTS:**
    
    **For 🟢 Compliant Scores:**
    Brief statement with rule citation.
    - Example: "**MKT.7** — Standardized Performance: 🟢 Compliant. Shows 1-, 5-, 10-year periods with proper disclosures."
    
    **For 🟡 Partially Compliant or 🔴 Non-Compliant Scores:**
    
    **YOU MUST INCLUDE THIS VERIFICATION BLOCK IN THE DELIVERABLE REPORT (not just internal analysis):**
    
    **Pre-Scoring Verification:**
    - **Step 1 — Rule Requirement:** [Exact quote from rule's checklist]
    - **Step 2 — Required Items:** [Only items rule explicitly requires]
    - **Step 3 — Exemptions:** [Exemptions checked; state if any apply]
    - **Step 4 — Document Match:** [For each item: ✓ Present / ✗ Absent with evidence]
    - **Step 5 — Score Determination:** [Logic from Steps 1-4]
    
    **Document Text:** [Quote relevant document section]
    
    **ENFORCEMENT:** If this verification block is missing or incomplete in the report for any 🟡 or 🔴 score → The score is invalid and must be corrected to 🟢 Compliant.
    
    **CRITICAL RULE:** If you cannot cite specific checklist text requiring something, you cannot mark it non-compliant for lacking it.
    
    **STRICT RULE ADHERENCE PROTOCOL:**
    - When a rule contains an explicit checklist (e.g., "Required disclosures must include..."), evaluate ONLY against those listed items
    - Do not add interpretive requirements not present in the rule text
    - If a concern exists that isn't covered by the specific rule's checklist, flag it under the appropriate general standard (e.g., SEC_206(4)_1.2 General Prohibitions, MKT.13 General Standards) rather than creating a technical violation where none exists
    - When the rule provides explicit scoring criteria (🟢/🟡/🔴), use them literally
    - Before marking any rule non-compliant, verify: (1) What does the rule's checklist explicitly require? (2) Are all those items present? (3) Is my concern actually in the rule's requirements, or am I adding something?
    ```

### 6. Comprehensive Compliance Report Generation

- Create Document Analysis Section:
  - Document type classification (reference Classification Guide category)
  - Target audience identified (retail, institutional, intermediary)
  - Issuer type identified (RIA, BD, fund company, etc.)
  - List of applicable regulatory frameworks with justification
  - List of non-applicable frameworks with justification
  - Summary of why specific regulations apply to this document
- Create Executive Summary:
  - Overall compliance posture
  - Total applicable frameworks (out of 21)
  - Total rules evaluated (triggered within applicable frameworks)
  - Critical violations count (🔴)
  - Partial compliance issues count (🟡)
  - Key findings and critical violations
- Generate Detailed Framework Sections:
  - One section per APPLICABLE regulatory framework
  - MANDATORY FORMAT: '**PREFIX.NUMBER** — Title: 🟢/🟡/🔴 Explanation'
  - Include framework overview and why it applies
  - Show all rules as triggered or 'Not Triggered'
- Create Statistics Table:
  - 🟢/🟡/🔴/Not Triggered counts for each applicable framework
  - List excluded frameworks with brief reason
  - Overall compliance percentage
- Generate Prioritized Recommendations:
  - Critical issues (🔴) first with specific rule citations
  - Partial compliance issues (🟡) second
  - Each recommendation with rule number: 'Violation of **MKT.3**' or '**FINRA_2212.8** non-compliant'
  - Prioritize by severity and materiality

### 7. DOCX Document Annotation with Tracked Changes

- IF the original input document is a DOCX file:
  - Load `scripts/word_document_editor.py` - the Word document editing utility
  - Create a working copy of the original DOCX file
  - For each compliance issue found (🔴 or 🟡 ratings):
    - Locate the specific text/section in document that triggered the violation
    - Add a comment using word_document_editor.py's search_and_comment() method
    - Comment format: "**RULE_ID**: [Violation description]. Severity: [Red/Yellow]. Recommendation: [Brief fix guidance]"
    - Comment author: "Compliance Review Agent"
  - For 🔴 (Red) violations where specific text changes would resolve:
    - Use word_document_editor.py's search_replace_track_changes() method
    - Add suggested corrections with track changes enabled
    - Track changes author: "Compliance Review Agent"
  - Preserve all original document content, formatting, and styles
  - Save annotated document as: "[original_name]_COMPLIANCE_REVIEW.docx"
  - Generate summary: Number of comments added, number of tracked changes suggested
  - Note: This step only applies to DOCX input files, not PDF or PPTX

### Completion

- Deliver complete compliance report with:
  - Document Analysis section with classification from guide
  - All applicable rules evaluated or marked as Not Triggered
  - Frameworks excluded with justification
  - Comprehensive statistics showing coverage across 21 frameworks
  - Actionable prioritized recommendations with rule number citations
- IF DOCX file: Also deliver the annotated DOCX file with:
  - Comments on all compliance issues (🔴 and 🟡)
  - Tracked changes with suggested corrections for violations
  - Summary of annotations made
- Ensure report is professionally formatted with clear section headers and consistent numbering