Regulatory Templates - Orchestrator

Overview

This skill orchestrates the regulatory template creation workflow through modular sub-skills, managing a 3-gate sequential validation process with dynamic context passing between gates.

Architecture: Modular design with dedicated sub-skills for each phase:

• regulatory-templates-setup - Initial configuration and selection
• regulatory-templates-gate1 - Regulatory compliance analysis and field mapping
• regulatory-templates-gate2 - Technical validation of mappings
• regulatory-templates-gate3 - Template file generation (.tpl)

Template Specifications: All template specifications are dynamically loaded within gates from centralized configurations. Templates are organized by regulatory authority with cascading selection:

BACEN (Banco Central):

• CADOC: 4010 (Cadastro), 4016 (Crédito), 4111 (Câmbio)
• APIX: 001 (Dados Cadastrais), 002 (Contas e Transações)

RFB (Receita Federal):

• e-Financeira: evtCadDeclarante, evtAberturaeFinanceira, evtFechamentoeFinanceira, evtMovOpFin, evtMovPP, evtMovOpFinAnual
• DIMP: v10 (Movimentação Patrimonial)

REQUIRED AGENTS: The sub-skills dispatch specialized agents:

• finops-analyzer - For Gates 1-2 and Discussion (regulatory analysis and validation)
• finops-automation - For Gate 3 (template file generation)

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Foundational Principle

Brazilian regulatory compliance (BACEN, RFB) has zero margin for error.

This isn't hyperbole:

• BACEN penalties for incorrect submissions: R$10,000 - R$500,000 + license sanctions
• RFB penalties for e-Financeira errors: Criminal liability for false declarations
• Template errors are discovered during audits, often months after submission
• "We'll fix it later" is impossible - submissions are final

This workflow exists because:

1. Human confidence without validation = optimism bias (proven by TDD research)
2. "Mostly correct" regulatory submissions = rejected submissions + penalties
3. Shortcuts under pressure = exactly when errors are most likely
4. Each gate prevents specific failure modes discovered in production

The 3-gate architecture is not bureaucracy - it's risk management.

Every section that seems "rigid" or "redundant" exists because someone, somewhere, cut that corner and caused a regulatory incident.

Follow this workflow exactly. Your professional reputation depends on it.

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When to Use

Use this skill when:

• User requests mapping and creation of Brazilian regulatory templates
• BACEN CADOCs (4010, 4016, 4111), e-Financeira, DIMP, APIX
• Full automation from analysis to template creation

Symptoms triggering this skill:

• "Create CADOC 4010 template"
• "Map e-Financeira to Midaz and set up in Reporter"
• "Automate DIMP template creation"

When NOT to use:

• Non-Brazilian regulations
• Analysis-only without template creation
• Templates already exist and just need updates

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NO EXCEPTIONS - Read This First

This workflow has ZERO exceptions. Brazilian regulatory compliance (BACEN, RFB) has zero margin for error.

Common Pressures You Must Resist

Pressure	Your Thought	Reality
Deadline	"Skip Gate 2, we're confident"	Gate 1 analysis ≠ Gate 2 validation. Confidence without verification = optimism bias
Authority	"Manager says skip it"	Manager authority doesn't override regulatory requirements. Workflow protects both of you
Fatigue	"Manual creation is faster"	Fatigue makes errors MORE likely. Automation doesn't get tired
Economic	"Optional fields have no fines"	Template is reusable. Skipping fields = technical debt + future rework
Sunk Cost	"Reuse existing template"	70% overlap = 30% different. Regulatory work doesn't tolerate "mostly correct"
Pragmatism	"Setup is ceremony"	Setup initializes context. Skipping = silent assumptions
Efficiency	"Fix critical only"	Gate 2 PASS criteria: ALL uncertainties resolved, not just critical

Emergency Scenarios

"Production is down, need template NOW" → Production issues don't override regulatory compliance. Fix production differently.

"CEO directive to ship immediately" → CEO authority doesn't override BACEN requirements. Escalate risk in writing.

"Client contract requires delivery today" → Contract penalties < regulatory penalties. Renegotiate delivery, don't skip validation.

"Tool/agent is unavailable" → Wait for tools or escalate. Manual workarounds bypass validation layers.

The Bottom Line

Shortcuts in regulatory templates = career-ending mistakes.

BACEN and RFB submissions are final. You cannot "patch next sprint." Every gate exists because regulatory compliance has zero tolerance for "mostly correct."

If you're tempted to skip ANY part of this workflow, stop and ask yourself: Am I willing to stake my professional reputation on this shortcut?

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Rationalization Table - Know the Excuses

Every rationalization below has been used to justify skipping workflow steps. ALL are invalid.

Excuse	Why It's Wrong	Correct Response
"Gate 2 is redundant when Gate 1 is complete"	Gate 1 = analysis, Gate 2 = validation. Different purposes. Validation catches analysis errors	Run Gate 2 completely
"Manual creation is pragmatic"	Manual bypasses validation layer. Gate 3 agent validates against Gate 2 report	Use automation agent
"Optional fields don't affect compliance"	Overall confidence includes all fields. Skipping 36% fails PASS criteria	Map all fields
"70% overlap means we can copy"	30% difference contains critical regulatory fields. Similarity ≠ simplicity	Run full workflow
"Setup is bureaucratic ceremony"	Setup initializes context for Gates 1-3. Skipping creates silent assumptions	Run setup completely
"Fix critical issues only"	Gate 2 PASS: ALL uncertainties resolved. Medium/low issues cascade to mandatory failures	Resolve all uncertainties
"We're experienced, simplified workflow"	Experience doesn't exempt you from validation. Regulatory work requires process	Follow full workflow
"Following spirit not letter"	Regulatory compliance requires BOTH. Skipping steps violates spirit AND letter	Process IS the spirit
"Being pragmatic vs dogmatic"	Process exists because pragmatism failed. Brazilian regulatory penalties are severe	Rigor is pragmatism
"Tool is too rigid for real-world"	Rigidity prevents errors. Real-world includes regulatory audits and penalties	Rigidity is protection

If You Find Yourself Making These Excuses

STOP. You are rationalizing.

The workflow exists specifically to prevent these exact thoughts from leading to errors. If the workflow seems "too rigid," that's evidence it's working - preventing you from shortcuts that seem reasonable but create risk.

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Workflow Overview

Flow: Setup → Gate 1 → Gate 2 → Gate 3 → Template Created ✅

Phase	Sub-skill	Purpose	Agent
Setup	regulatory-templates-setup	Template selection, context init	—
Gate 1	regulatory-templates-gate1	Regulatory analysis, field mapping	finops-analyzer (opus)
Gate 2	regulatory-templates-gate2	Validate mappings, test transformations	finops-analyzer (opus)
Gate 3	regulatory-templates-gate3	Generate .tpl template file	finops-automation (sonnet)

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Orchestration Process

Step 1: Initialize TodoWrite with 5 tasks (setup, gate1, gate2, gate3, verify)

Step 2-5: Execute each sub-skill using Skill tool:

Step	Skill	On PASS	On FAIL
2	regulatory-templates-setup	Store context → Gate 1	Fix selection issues
3	regulatory-templates-gate1	Store spec report → Gate 2	Address critical gaps, retry
4	regulatory-templates-gate2	Store finalized report → Gate 3	Resolve uncertainties, retry
5	regulatory-templates-gate3	Template complete	401=refresh token, 500/503=wait+retry

Context flows in memory - no intermediate files created

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Context Management - Report-Driven Flow

Context accumulates through gates (each adds, never overwrites):

After	Context Additions
Setup	template_selected, template_code, authority, deadline
Gate 1	specification_report (template_info, fields, transformations, validations, structure)
Gate 2	finalized_report (validated, uncertainties_resolved, all_fields_mapped, ready_for_implementation)
Gate 3	gate3 (template_file, filename, path, ready_for_use, report_compliance: 100%)

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Template Specifications Management

• Gates load specs dynamically from centralized config
• Add new templates by adding specifications only (no new skills)
• Pattern: loadTemplateSpecifications(templateName) for field mappings, validation rules, format specs

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State Tracking

Output after EACH sub-skill: SKILL: regulatory-templates | PHASE: {phase} | TEMPLATE: {template} | GATES: {n}/3 | CURRENT: {action} | NEXT: {next} | BLOCKERS: {blockers}

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Error Handling

Error	Action
Gate failure (retriable)	Fix issues → retry gate
Gate failure (non-retriable)	Escalate to user
Gate 3: 401	Refresh token → retry
Gate 3: 500/503	Wait 2 min → retry

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Coordination Rules

1. Sequential execution (1→2→3)
2. Context accumulates (never overwrites)
3. Failure stops progress
4. State tracking after each sub-skill
5. TodoWrite updates immediately
6. NO intermediate files (memory only)
7. SINGLE output file (.tpl in Gate 3)

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Red Flags - STOP Immediately

If you catch yourself thinking ANY of these, STOP and re-read the NO EXCEPTIONS section:

Skip Patterns

• "Skip Gate X" (any variation)
• "Run Gates out of order"
• "Parallel gates for speed"
• "Simplified workflow for experienced teams"
• "Emergency override protocol"

Manual Workarounds

• "Create template manually"
• "Copy existing template"
• "Manual validation is sufficient"
• "I'll verify it myself"

Partial Compliance

• "Fix critical only"
• "Map mandatory fields only"
• "Skip setup, we already know"
• "Lower pass threshold"

Justification Language

• "Being pragmatic"
• "Following spirit not letter"
• "Real-world flexibility"
• "Process over outcome"
• "Dogmatic adherence"
• "We're confident"
• "Manager approved"

If You See These Red Flags

1. Acknowledge the rationalization ("I'm trying to skip Gate 2")
2. Read the NO EXCEPTIONS section (understand why it's required)
3. Follow the workflow completely (no modifications)
4. Document the pressure (for future skill improvement)

The workflow is non-negotiable. Regulatory compliance doesn't have "reasonable exceptions."

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Quick Reference

Sub-skill	Purpose	Input	Output
regulatory-templates-setup	Initial configuration	User selections	Base context
regulatory-templates-gate1	Regulatory analysis	Base context	Field mappings, spec report
regulatory-templates-gate2	Technical validation	Context + Gate 1	Validated mappings, rules
regulatory-templates-gate3	Template creation	Context + Gates 1-2	.tpl file

Checklist

Before: Sub-skills exist, agents available, template selected, URLs configured After each gate: Result captured, context updated, TodoWrite updated, state tracked After completion: Template created, verified, user notified