{
  "tool_id": "art-536-reg-w-affiliate-transaction-tester",
  "inventory_version": "1.0.0",
  "authored_at": "2026-08-23",
  "authored_by": "AUTHORING-STANDARD-ADOPT-1",
  "cohort_role": "gapped, with a working kill condition — chosen because it pins SIX clause snapshots of which FOUR are exemption or inapplicability lists (223.14(f), 223.15(b), 223.16(c), 223.41, 223.42). It tests whether a node that already refuses well on ONE axis (undeclared policy) refuses at all on the axis its own citations are mostly about.",
  "error_direction": "conservative_toward_finding",
  "error_direction_rationale": "The tests are against CAPS — the 10% single-affiliate and 20% aggregate limits of section 23A, and the collateral ladder of 223.14(b). Because no exemption branch is exercised, a transaction that IS exempt is measured against the caps anyway, so the node over-reports breaches rather than missing them. That is the safe direction here, and it is safe by accident rather than by design: the same omission would be the harmful direction in a node whose exemptions widened rather than narrowed the tested population.",
  "derived_from": [
    { "digest": "sha256:a3cf2246a016eff040a53cfeec80ea34742b8bc9ecd6bdc17f195ec35e477096", "clause_path": "223.14(b)(1)(i)-(iv), (c), (d)" },
    { "digest": "sha256:3c46d7df5c5d9e4e5d97212218051610543e9d52fbaa2dc618aa46656947cbf2", "clause_path": "223.14(f)(1)-(3)" },
    { "digest": "sha256:ad5d91318b31c688ac6b805e2c649c0546ae1a84a6a7e13a2954e088ad836651", "clause_path": "223.15(a)-(b)" },
    { "digest": "sha256:c9527ebf137eca82b261f92212e6e2468127b276be963c3f9d74e9fcc7d9818d", "clause_path": "223.16(c)" },
    { "digest": "sha256:e66b72f9d391214a87925ca5dbc2a2c4ed3b6431c917705518285dd78debc5c9", "clause_path": "223.41" },
    { "digest": "sha256:17beda64e1d58cb65e59b03136a1651e8f625bd1309a134b583db48cf993fca4", "clause_path": "223.42" }
  ],
  "branches": [
    {
      "id": "reg-w-single-affiliate-quantitative-limit",
      "clause": "12 CFR 223.11",
      "branch": "Covered transactions with any ONE affiliate are limited to 10 percent of the member bank's capital stock and surplus.",
      "disposition": "represented",
      "evidence": "single_affiliate_tests"
    },
    {
      "id": "reg-w-aggregate-quantitative-limit",
      "clause": "12 CFR 223.12",
      "branch": "Covered transactions with ALL affiliates in the aggregate are limited to 20 percent of capital stock and surplus.",
      "disposition": "represented",
      "evidence": "aggregate_test"
    },
    {
      "id": "reg-w-223.14b1-collateral-ladder",
      "clause": "12 CFR 223.14(b)(1)(i)-(iv)",
      "branch": "A covered credit transaction must be secured by collateral with market value of at least 100/110/120/130 percent of the amount, stepping with the collateral class.",
      "disposition": "represented",
      "evidence": "collateral_tests"
    },
    {
      "id": "reg-w-223b-market-terms",
      "clause": "12 CFR part 223 subpart F (section 23B)",
      "branch": "The transaction must be on terms and under circumstances substantially the same as those for comparable non-affiliate transactions.",
      "disposition": "represented",
      "evidence": "market_terms_declarations"
    },
    {
      "id": "reg-w-policy-parameters-undeclared",
      "clause": "12 CFR 223.11-223.12 (capital stock and surplus as the denominator)",
      "branch": "Every quantitative test is a ratio to capital stock and surplus. Without the declared capital base and limit percentages there is no denominator, so there is no test.",
      "disposition": "refused",
      "refusal": {
        "flag": "REG_W_KILL_CONDITION_INCOMPLETE_DECLARATION",
        "payload_marker": "reason",
        "fixture": "art-536-reg-w-affiliate-transaction-tester.fixtures.json#no_policy_declared_did_not_run",
        "reachability_vector": {
          "transactions": [
            { "affiliate_id": "affiliate-alpha-holdings", "transaction_id": "txn-0301", "transaction_type": "credit", "amount": 100000, "collateral_value": 100000, "market_terms_substantially_same": true }
          ]
        }
      },
      "note": "The estate's absence-instrument discipline working as designed: execution_state becomes 'did_not_run', decision is null, and reason names the missing declaration. This is the ONE refusal path in the node, and it covers the input axis rather than the exemption axis."
    },
    {
      "id": "reg-w-223.14f-collateral-requirement-inapplicable",
      "clause": "12 CFR 223.14(f)(1)-(3)",
      "branch": "The collateral requirements DO NOT APPLY to: an acceptance already fully secured by attached documents or other involved property with an ascertainable market value; the unused portion of certain extensions of credit; and the third listed class.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_finding",
      "note": "⛔ FINDING. The collateral ladder is applied to every credit transaction the caller supplies; no input distinguishes a 223.14(f) transaction, so a collateral shortfall is reported for a transaction the rule exempts from the requirement entirely."
    },
    {
      "id": "reg-w-223.15b-problem-loan-participation-renewal",
      "clause": "12 CFR 223.15(b)(1)-(…)",
      "branch": "The low-quality-asset purchase prohibition does not apply to the renewal of, or additional credit on, a participation in a loan to a nonaffiliate originated by an affiliate, where the enumerated conditions hold.",
      "disposition": "unrepresented_known",
      "error_direction": "undirected",
      "note": "⛔ FINDING, and a compound one: the node represents neither the 223.15(a) prohibition NOR its (b) exemption. A branch that is absent on both sides is invisible to any test that looks only for over- or under-reporting."
    },
    {
      "id": "reg-w-223.16c-deemed-affiliate-transaction-exemptions",
      "clause": "12 CFR 223.16(c)",
      "branch": "Transactions treated as affiliate transactions under 223.16(a) are NOT subject to the 223.11/223.12 quantitative limits or the 223.14 collateral requirements where they fall in the (c) list — riskless principal transactions among them — while remaining subject to 223.13 and to section 23B.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_finding",
      "note": "⛔ FINDING. Note the shape: (c) removes the quantitative and collateral legs but KEEPS the market-terms leg. A faithful representation is therefore not a single exempt/not-exempt flag but a per-leg one, which is the kind of structure an inventory surfaces and a boolean never would."
    },
    {
      "id": "reg-w-223.41-exempt-from-limits-collateral-and-lqa",
      "clause": "12 CFR 223.41(a)-(d)",
      "branch": "Covered transactions exempt from the quantitative limits, the collateral requirements AND the low-quality-asset prohibition: parent/subsidiary institution transactions; transactions between a member bank and a depository institution under the same holding company; certain loan purchases from an affiliated depository institution; and internal corporate reorganization transactions meeting the six (d) conditions.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_finding",
      "note": "⛔ FINDING. Four branches, none reachable. (d)'s six conditions are the sort of multi-predicate carve-out that AUTHORING-STANDARD.md §1.3 would discharge as a refusal naming the predicates, exactly as art-615 does for the MLA short-term carve-out."
    },
    {
      "id": "reg-w-223.42-exempt-from-limits-and-collateral",
      "clause": "12 CFR 223.42(a)-(k)",
      "branch": "Eleven further classes exempt from the quantitative limits and collateral requirements: correspondent banking deposits; credit for uncollected items; transactions secured by cash or US obligations; purchases of a servicing affiliate's securities; certain liquid assets; certain marketable securities (six conditions); municipal securities (three conditions); credit purchased subject to a repurchase agreement; asset purchases by a newly formed member bank; Bank Merger Act approvals; and purchases of an extension of credit from an affiliate.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_finding",
      "note": "⛔ FINDING, and the largest single gap in the cohort: eleven head-of-provision exemption classes, several with their own multi-condition tests, pinned as a clause snapshot and exercised by nothing. This is the enumeration audit's dominant vector in one citation."
    },
    {
      "id": "reg-w-capital-base-and-limits",
      "clause": "12 CFR 223.11-223.12",
      "branch": "The capital stock and surplus figure and the 10/20 percent limits.",
      "disposition": "out_of_scope_by_input",
      "assumption_of_use": {
        "value": "the declared Reg W policy parameters (capital base, single-affiliate limit, aggregate limit) and policy_vintage",
        "source": "12 CFR 223.11-223.12",
        "owner": "the CALLER. Discharged better than most: absence is refused rather than defaulted, and the vintage travels in the payload. Nothing validates that the declared vintage matches the transaction dates."
      }
    }
  ]
}