Gemini Consulates | OppFi
Compliance & Risk
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The "Regulatory Plain-English Translator" (Prompt)

Because "notwithstanding the provisions of subsection (b)" is not a strategy.


CONTEXT

Use this prompt when you have a regulatory update or rule excerpt that is technically impenetrable and you need to quickly brief non-legal stakeholders on the operational implications and the key decisions required.

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]

WHAT IT DOES

Regulatory updates land in inboxes and sit unread because they're impenetrable. This prompt bridges the gap between legal language and business action — not by replacing legal review, but by making it faster. Product, engineering, and marketing teams can understand the "so what" before the lawyers have finished the formal memo.


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