feat: CR-BP-74 F&A Retire escape-clause discovery (Regulated Run-Off) - #115
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emmanuel-a-otchere merged 1 commit intoSep 15, 2026
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Escape-clause re-evaluation of the F&A x Retire register cell,
re-opening the verbatim escape condition from the register v2
ratification (CR-BP-19, 2026-09-07):
'defer until a regulated unwind (e.g. mutual insurer run-off)
requires a standalone group'
The 2024-2026 regulatory landscape satisfies the escape clause:
- PRA PS20/24 (UK): Solvent Exit Planning for Insurers, in
force 30 June 2026. 28-day run-off plan once supervised.
- FSB Final Guidance on Insurance Resolution Strategies (2025):
categorises run-off as solvent, insolvent, payout/transfer,
and liquidation.
- NAIC Model Regulation Service of Legal Process (Model 901):
record retention during run-off; service-of-process;
claims-handling.
- IFRS 17 Insurance Contracts (effective 2023): current
fulfillment value with contractual service margin; the General
Model, the Variable Fee Approach, and the Premium Allocation
Approach each define how policies in run-off are measured.
- IFRS 5 Non-current Assets Held for Sale and Discontinued
Operations.
- ASC 205-30 Liquidation Basis of Accounting (FASB ASU 2013-07);
ASC 944 Financial Services - Insurance.
- APQC PCF 8.8 Perform financial wind-down (entity-level
solvent exit).
- TM Forum eTOM GB921 Level 3: 1.1.3.4 Manage Financial
Liquidity; 1.4.5 Perform Wind-down; 1.4.6 Perform Disposal
of Investments.
- Insurance Run-off Association (IRO) Best Practice Guidance
(2024): governance, communications, claims handling, asset
management during run-off, reserving adequacy, capital
adequacy during wind-down.
- dea-metaframework/framework/domain-grounding.md section 3.7.
Outcome (4 candidates evaluated):
- Conclude a Regulated Run-Off: 9/10 ADMIT-CANONICAL
- Operate Financial Wind-Down: 5/10 DEFER
- Dispose of Investments: 3/10 RECLASSIFY
- Recognize Impairment and Exit Liabilities: 3/10 RECLASSIFY
Candidate 1 is the L1 Process to admit at F&A x Retire via
CR-BP-75. It satisfies BP-LIFE-009 (verb + object), BP-ARC-ID-001
(process_type: management), DISC-002 (post-IFRS-17 evidence
basis), DISC-003 (authority-anchored trigger), and DISC-005
(audit completeness). Score 9/10; one-point reduction for the
F&A-domain scope question (insurance-led vs broader financial-
stewardship wind-down), deferred to a future CR.
Candidate 2 fails the BP-LIFE-009 semantic-identity test
(Operate is a state verb, not a transformation verb). Defer
until a future CR re-evaluates the cell charter to include a
non-insurance regulated wind-down L1 candidate (banks under
PRA BRRD / FDIC OLA, pension funds under PBGC termination).
Candidates 3 and 4 are Activity-shaped (bounded to a single
disposal or recognition event under the broader run-off
Process). Reclassify as Activity-level decomposition
candidates for CR-BP-7x+ once candidate 1 is admitted.
Schema notes:
- context_evaluation uses boolean concern-was-identified flags
(concerns_identified, candidates_considered, etc.); the
A&O escape record at CR-BP-72 uses the same pattern.
- rationale.{included,excluded,unresolved} are multi-line
string scalars (schema requires type=string, not array).
- scoring.total is an integer 0-10 (schema constraint),
decomposed into the 5 required sub-scores
(process_reality, semantic_stability,
cross_domain_applicability, boundary_clarity,
evidence_strength).
- disposition.canonical_process_ref is type=string (not
nullable); field is omitted entirely for DEFER / RECLASSIFY
dispositions.
- evaluation has 14 required fields; process_identity and
registry_alignment are removed (they were content, not
schema fields).
Repository:
- discovery/v1-alpha/finance-and-accounting-retire-escape.yaml
(NEW; escape-clause re-evaluation per CR-BP-62 method)
- tests/test_check_lifecycle_discovery.py (MOD: 16 -> 17
across 3 sites: record_count, docstring 'Discovery
records checked: 16' -> 17, len(_stage_pairs))
- change-requests/CR-BP-74-fa-retire-escape-discovery.md (NEW)
- change-requests/README.md (MOD: index row)
Verified:
- check_lifecycle_discovery.py CONFORMANT, 17 records, 0
findings
- pytest 383/0 (15/15 in test_check_lifecycle_discovery.py)
- 0 schema errors against
schemas/discovery/lifecycle-discovery.schema.json
- 0 em-dash on new lines (memory directive 2026-09-11)
- No admission; ADMIT-CANONICAL is recommendation-only per
CR-BP-62 section 20; admission is CR-BP-75
- No PC, PG, BP, or activity files created
- No register cell flip (carried to CR-BP-75)
- No ADM-001 regex extension
- No disposition register append
- No tranche plan update
- No PG, BP, or activity count-assertion bump
- No CATALOG.yaml regeneration
- No CR-META changes
Branch cut from origin/main post-#114; not stacked on open PRs.
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Escape-clause re-evaluation of the F&A x Retire register cell, re-opening the verbatim escape condition from the register v2 ratification (CR-BP-19, 2026-09-07):
'defer until a regulated unwind (e.g. mutual insurer run-off) requires a standalone group'
The 2024-2026 regulatory landscape satisfies the escape clause: PRA PS20/24 (UK, in force 30 June 2026), FSB Final Guidance on Insurance Resolution Strategies (2025), NAIC Model 901 (US), IFRS 17 (effective 2023), ASC 205-30 Liquidation Basis, IRO Best Practice Guidance 2024.
Outcome (4 candidates)
Candidate 1 is the L1 Process to admit at F&A x Retire via CR-BP-75. It satisfies BP-LIFE-009 (verb + object), BP-ARC-ID-001 (process_type: management), DISC-002 (post-IFRS-17 evidence basis), DISC-003 (authority-anchored trigger), and DISC-005 (audit completeness).
Candidate 2 fails the BP-LIFE-009 semantic-identity test (Operate is a state verb, not a transformation verb). Defer until a future CR re-evaluates the cell charter to include a non-insurance regulated wind-down L1 candidate (banks under PRA BRRD / FDIC OLA, pension funds under PBGC termination).
Candidates 3 and 4 are Activity-shaped. Reclassify as Activity-level decomposition candidates for CR-BP-7x+ once candidate 1 is admitted.
Verified
NOT-list: no PC, PG, BP, or activity files; no register cell flip; no ADM-001 extension; no disposition register append; no tranche plan update; no count-assertion bump; no CATALOG.yaml regeneration; no CR-META changes. ADMIT-CANONICAL is recommendation-only per CR-BP-62 section 20; admission is CR-BP-75.
Next step (separate slice): CR-BP-75 admission tranche.