To war-game a regulatory filing before you submit it, put the draft filing or application, the board materials it should match, the internal reports an examiner could request, and any prior correspondence with the agency into one request. Then instruct Pingpong to read the filing the way a careful examiner would: find statements that conflict with your own documents, claims about controls that an audit report could undercut, and answers likely to prompt follow-up questions. Ask for every inconsistency and every question that should go to counsel before the filing is final. Pingpong tests the narrative and the questions. Your lawyers decide what the filing must say.
This page is for chief executives, chief financial officers, general counsel, and board committee chairs preparing a license application, an agency notification, an industry regulator filing, or a disclosure document. For a public announcement written for reporters and customers, see war-game a press release before the announcement goes out. Executive starting points live under Pingpong for executives.
What Pingpong checks, and what counsel decides
Useful work for a review:
- Figures that differ between the filing, the board deck, and the budget.
- Descriptions of reporting lines, controls, or systems that internal documents contradict.
- Plans described in the filing that the board has not approved.
- Vague answers likely to draw a follow-up request.
- A list of questions an examiner might ask, with the document that would answer each.
Decisions that belong with counsel:
- Whether a past matter must be disclosed and how to describe it.
- Legal standards, thresholds, and deadlines that apply to the filing.
- Wording that creates commitments to the agency.
- Privilege, confidentiality requests, and what to share with the reviewing models in the first place.
A worked example
This example is illustrative and does not describe a customer. A 220-person payments company is applying for a money transmission license in a new state. The application includes a business plan, three-year projections, a description of the compliance program, and answers about prior regulatory matters. The audit committee wants to see the final version before submission.
The chief financial officer pastes the draft application, the board-approved budget, the compliance organization chart, the most recent internal audit summary, and the list of prior regulatory correspondence.
A useful pass finds that projected transaction volume for the new state is about three times the figure in the board budget, because the application used the sales team's planning case. The application says the chief compliance officer reports to the audit committee, while the organization chart shows a reporting line to the general counsel with quarterly briefings to the committee. The compliance section calls transaction monitoring fully automated, but the internal audit summary describes a backlog of 2,000 alerts waiting for manual review.
The pass also notes that the business plan mentions a digital asset feature in year two, which the board has discussed but not approved and which may raise separate licensing questions. The answer about prior matters says "none," while the correspondence list includes a warning letter from another state regulator two years ago that was closed without action. The pass flags that one for counsel rather than suggesting an answer. The capital figure comes from an unaudited quarter.
The team revises before the audit committee meeting. Projections now match the board budget, with the sales case shown as an upside scenario. The compliance reporting line is described as it actually works. The monitoring description explains the manual review step, the backlog, and the remediation plan with a target date. The digital asset feature comes out of the plan. Counsel decides how to answer the prior matters question and approves the wording. The capital figure uses the audited year-end statement. The chief financial officer prepares a list of 15 likely examiner questions with the supporting document for each.
A request you can copy
Below are a draft regulatory filing, the board materials and budget it should match, internal audit and control reports, and our prior correspondence with regulators. Read the filing as a careful examiner. List every statement that conflicts with our documents, every description of controls that an internal report could undercut, every plan the board has not approved, and every answer likely to draw a follow-up request. Do not decide legal questions. Mark each one for our counsel instead. Finish with likely examiner questions and the document that would answer each.
How Pingpong runs the war-game
The web review app sends your request through several models in order. Each later model receives the original request and every earlier answer, with instructions to assess the work so far. Check with counsel before you paste privileged material. For the steps inside the app, see running your first review.
What a model can't war-game
A model cannot replace your counsel or compliance team. It does not know the agency's current priorities, how this examiner has treated similar filings, or which rules apply to your facts. Use it to find inconsistencies and questions, and let counsel own every answer that goes to the regulator.
When the filing needs board approval, see war-game a decision before the board meeting. More guides live under work decisions before you commit.