How we build the library — and how we keep it honest.
Last updated: May 2026
The regulatory obligation library is the spine of NomisFile. Every customer’s calendar is assembled from it. This page documents how those obligations get into the library, how we keep them current, and what we are — and are not — committing to when we cite a statute or surface a rule change.
Coverage at a glance
Counts below are pulled live from the library at request time — not hard-coded copy. If the page says it, the database says it.
Drafts are obligations our curation team has sourced but not yet approved. They do not surface in any customer’s calendar until a reviewer signs off on the citation and effective date. See “Confidence levels” below.
Citation integrity, in the open
Across the 752 active templates in the library, here is exactly where each one stands on citation, source link, independent verification, and confidence. We show the work-in-progress figures rather than only the finished ones — a template still being verified is labelled that way, not hidden.
| Confidence | Share of active library |
|---|---|
| High | 1.9% (14) |
| Medium | 17.7% (133) |
| Low — in active verification | 80.5% (605) |
Most of the library sits at low confidence today: drafted from regulatory research and awaiting a reviewer’s primary-source check. We would rather tell you that plainly than imply a verification level we haven’t reached. These figures move as the rolling review described below works through the set.
Every obligation in your calendar carries this provenance panel, so you can see exactly where a given entry stands:
Provenance signals are informational, not legal advice. Confirm applicability and the current rule with the primary source and your counsel.
Example values only. When a field hasn’t been verified yet, the panel says so — e.g. “Not yet independently verified” — rather than leaving a blank.
Our sourcing process
Every obligation in the library starts at a primary source published by the regulator with authority over it. We do not cite secondary summaries; we cite the statute, administrative code, or final-rule publication.
- State regulators. State Department of Banking, Department of Financial Institutions, or equivalent — the office that issued the license type.
- Federal Register — final-rule publications for FinCEN, CFPB, FTC, OCC, OFAC.
- NYDFS industry letters and rulemaking pages (23 NYCRR Parts 200, 500, 504).
- FinCEN guidance, advisory bulletins, and SAR/CTR rules.
- OFAC Recent Actions feed and civil-enforcement information.
- CFPB rules-under-development page and Regulation E (12 CFR Part 1005).
Every approved obligation row carries:
- The exact citation as published (statute or admin-code chapter and section).
- A direct URL to the primary source — the page a reviewer would click first.
- A reviewer attribution (who approved, when).
- A last-reviewed-at timestamp so freshness is visible.
- An obligation-source tag (which curation batch or seed produced the row).
Update cadence
Three streams feed library updates:
- Reg Watch — we track upcoming regulatory effective dates against your license footprint and surface them with their source citations. See /reg-watch for the live feed.
- Quarterly library review — on a rolling cadence we re-verify a slice of the approved set against primary sources and update the last-reviewed-at timestamp. The distribution below shows how much of the live library has been re-verified recently.
- Customer-driven additions — if your license footprint touches a regulator we don’t cover, tell us. We’ll add the citation and ship the template — usually within seven days.
Re-verification freshness
Live distribution of last_reviewed_at across the approved set. Rows that have never been re-verified after initial seeding (or that lack a last_reviewed_at value) count as “older than 180 days” here, not as “fresh.” This is intentional — the page would rather underclaim than overclaim.
| Bucket | Rows |
|---|---|
| Re-verified within last 90 days | 41 |
| 91–180 days | 0 |
| Older than 180 days, or never re-verified | 327 |
Confidence levels
Every row in the library carries a review_status. Customers only see approved rows in their calendars.
| Status | Meaning | Customer-visible? |
|---|---|---|
| approved | Citation verified against primary source by a human reviewer. Lands in customer calendars. | Yes |
| draft | Sourced from a regulator publication; waiting for a reviewer to verify citation and effective date. | No |
| rejected | Reviewer found the citation incorrect, the rule withdrawn, or scope wrong. Kept in the database for audit, never surfaced. | No |
What we are not
A short, honest list.
- We are not a law firm. Nothing in NomisFile is legal advice. The library is a tracking tool, not counsel.
- The library is not exhaustive. We focus on money transmission, money services businesses, and adjacent fintech regulation across the United States. If a regulator you file with isn’t covered yet, we’ll add them — just ask.
- An approved citation is not a guarantee of applicability. Whether an obligation applies to your specific entity is a function of your license footprint, business model, and counsel’s judgment. NomisFile surfaces the obligation; the applicability call is yours.
- We do not replace examiner-issued first day letters. Exam-prep evidence packets organize what you already have; they do not substitute for direct regulator correspondence.
For the full legal terms governing your use of NomisFile, see /terms.
Want to see what’s changing?
/reg-watch lists upcoming regulatory effective dates against the license footprint you’ve loaded. Each row carries its source citation. Human-reviewed — what’s changing, not autonomous calendar edits.