Change impact note
- 4 changes assessed; 3 alter what staff must do.
- Accepted and material: 0.
Legal Intelligence
Regulatory and Legal Change Impact
Connects verified regulatory developments to the contracts, processes, policies, entities and obligations they affect, and opens a governed review.
Demonstration: Rosewell Capital Management (fictional) · Asset management. Fictional data and a scripted answer.
The situation
- Organisation
- Rosewell Capital Management (fictional)
- Who is asking
- Compliance counsel
- Industry
- Asset management
- What happened
- A regulator has published a revised client-money rule, and the firm's policy refers to the old wording.
The question asked
Which parts of our client-money policy must change to reflect the revised rule, and which changes alter what staff must do?
What it reads, and who can see the result
- Revised rule text (synthetic) documentThe new wording compared with the old.
- Internal policy documentThe firm's current policy.
- Reads
- The two versions of the rule and the policy text.
- Does not read
- Client records.
- Permission
- Compliance read access.
- Who sees it
- Compliance, operations and the board's risk committee.
Try it
Accept or reject each change. The text below is rebuilt from the changes you accept, and changes that alter what people must do are marked.
Client money policy, v6 (current)
Client money is held in segregated accounts at approved banks.
Added
Each bank's credit standing is reviewed at least annually and the review minuted.
Records an existing practice.
Reconciliations are carried out monthly.
Reworded Changes what people must do
Reconciliations are carried out daily.
Operations must run daily reconciliations; the monthly team cannot meet this.
Breaches are reported to the compliance officer when identified.
Reworded Changes what people must do
Breaches are reported to the compliance officer within one business day of being identified.
Introduces a deadline for staff reporting.
Client money may be held with a single bank.
Removed Changes what people must do
The revised rule requires diversification across at least two banks.
The text after your decisions (4 lines)
- Client money is held in segregated accounts at approved banks.
- Reconciliations are carried out monthly.
- Breaches are reported to the compliance officer when identified.
- Client money may be held with a single bank.
The answer
Simulated answer. Written for this fictional case, not produced by a live model. Only the figures in it are computed, from what you decided above.
4 changes follow from the revised rule; 0 accepted, 0 rejected, 4 undecided.
Each proposed change cites the point in the revised rule that requires it [S1]. Three change what staff must do: daily reconciliation, a one-day reporting deadline, and the end of single-bank holding [S2].
A change that alters what people must do has an effect beyond the document: training, systems and capacity. 0 of the changes you accepted are of that kind and need an implementation plan before the policy takes effect.
Relies on: S1 · Synthetic Client Money Rules, revisedS2 · Client money policy v6
Review and approval
The compliance counsel decides. Approving sends the revised policy for sign-off by the risk committee. It does not bring the revised rule into effect or assert compliance.
Not ready to approve. 4 changes are still undecided. Accept or reject each one first.
In the product this is a different person with the right permission. Here you play that role to see the rule.
What it produces
Implementation
- Plan the move to daily reconciliation with operations before the effective date.
Limits of this example
- The comparison uses synthetic rule text; the proposed wording is a drafting aid for counsel.
- Effective dates and transitional provisions are for counsel to confirm.
- This is a scripted demonstration on fictional data. No model was called and no real organisation, person or result is shown.
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