List the facts a no-action request would have to state

Key facts

Human involvement
RedLawyer-led
How AI is used
List, from the file, the product, service, or action the request would describe, and the facts and representations the file already records. Do not write the request, and do not say that the staff have granted relief.
What the lawyer must review
You write any request that is sent. The Commission's no-action page describes these letters as correspondence from Commission staff in response to requests for no-action, interpretive, or exemptive letters. The Investor.gov glossary says a person who is not certain whether a product, service, or action would violate the federal securities laws may request a no-action letter. Most letters describe the request, analyse the facts, discuss the applicable laws, and, if the staff grant the request, conclude that the staff would not recommend that the Commission take enforcement action against the requester based on the facts and representations in the request. The staff sometimes respond with an interpretive letter. Relief is based on the specific facts. In some cases the staff may permit a third party to rely on it where that party's facts are substantially similar. The staff reserve the right to change positions taken in earlier letters. The opened pages do not say that a staff letter is an action of the Commission.
Written for / version
United States versionUSCth

Who does what

Who does what
RoleWhat they do
AssistanceSupporting preparation only. Consider narrowly defined preparation support after confirming the tool’s capability and permitted scope. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human.
LawyerPerform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use.

Checklist

  1. Confirm that the wording reflects the client’s instructions and contains no unintended admission, concession or commitment. Check the recipient and tone.
  2. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  3. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

Related tasks

Related tools

Related jurisdictions