comments

/comments

Purpose

Consultas públicas e tomadas de subsídios have deadlines (prazo de participação). The decision to file a contribuição or not is an attorney call — but the deadline disappearing without a logged decision is the risk. This skill surfaces open participation periods and records decisions.

Under Brazil's Lei Geral das Agências Reguladoras (Lei 13.848/2019), the agências reguladoras must open the regulatory process to social participation: consulta pública (written contributions on a proposed act, art. 9 [settled — last confirmed 2026-07-03]) and audiência pública (an oral public hearing the agency may convene on a relevant matter, art. 10 [settled — last confirmed 2026-07-03]). Beyond these statutory instruments, agencies may create others by regimento interno (art. 11) — the tomada de subsídios (early-stage input-gathering before a proposal is drafted) is one such regimental instrument that the ANPD in particular uses, alongside its consultas públicas, on data-protection regulamentações under the LGPD [model knowledge — verify — tomada de subsídios is agency-regimental, not in Lei 13.848]. Participation is generally written, submitted via the agency's electronic portal (Participa + Brasil / the agency's own consulta system) within the published prazo.

Load context

~/.claude/plugins/config/claude-for-legal/regulatory-legal/comment-tracker.yaml → all tracked consultas/tomadas de subsídios and their status. ~/.claude/plugins/config/claude-for-legal/regulatory-legal/CLAUDE.md → default comment decision owner.

Default view — open participation periods

## Consulta / Tomada de Subsídios Tracker — [date]

### ⏰ Deadline in <14 days

| ID | Regulation | Deadline | Days left | Decision | Owner |
|---|---|---|---|---|---|
| CMT-001 | [name] | [date] | [N] | Undecided | [owner] |

### 🟡 Open (>14 days)

[same table]

### Recently decided

| ID | Regulation | Decision | Rationale |
|---|---|---|---|
| CMT-002 | [name] | Not filing | [reason] |

---

**Total open:** [N]  **Undecided with deadline <30 days:** [N]

Log a decision

/regulatory-legal:comments --decide CMT-001
Decision: [filing / not-filing / waived]
Rationale: "[brief — e.g., 'Rule doesn't apply to our model' or 'Filing comment on Section 3']"

Updates tracker. If decision is "filing": prompt for filing deadline reminder (comment deadline minus 5 business days for internal review).

Notifications

On first detection of a consulta pública / tomada de subsídios (populated by reg-feed-watcher): Slack DM to comment decision owner if Slack MCP is configured and owner_slack is set.

Reminder at 14 days before deadline if decision is still "undecided." Reminder at 3 days before deadline if still undecided — elevated urgency.

Consequential-action gate (submit a regulatory comment / respond to a regulator)

Before logging a decision as "filing" — and always before producing a comment letter or regulator-response draft for submission: Read ## Who's using this in ~/.claude/plugins/config/claude-for-legal/regulatory-legal/CLAUDE.md. If the Role is Non-lawyer:

Submitting a contribuição or response to an agência reguladora has legal consequences. It's a public statement of the company's position, it goes on the record in the processo regulatório or enforcement matter, and positions taken here bind the company and can be used against it in subsequent proceedings. Have you reviewed this with an attorney? If yes, proceed. If no, here's a brief to bring to them:

• The processo regulatório or inquiry (agência reguladora, nº do processo/consulta, prazo)
• What the proposed contribuição/response says and on what sections
• Open questions and what's unresolved
• What could go wrong (adverse admissions, inconsistent prior positions, coordination-of-comment concerns with associações setoriais)
• What to ask the attorney (should we file at all; should we file jointly through an associação/entidade de classe; are there positions we should not take)

If you need to find a lawyer: the OAB (Ordem dos Advogados do Brasil) seccional of your estado is the starting point — its Comissão de sociedade/serviço de referência or the local subsecção can point you to counsel. (For a foreign regulator: that jurisdiction's professional body — state bar in the US; SRA/Bar Standards Board in England & Wales; or the local equivalent.)

Do not log a "filing" decision or produce a submission-ready draft past this gate without an explicit yes. Tracking views, deadline reminders, and "not-filing / waived" decisions do not require the gate.

---

What this skill does not do

• Draft the contribuição. That is a separate attorney task.
• Make the filing decision. It tracks the decision; the attorney makes it.
• Monitor post-comment activity. Once a decision is filed, this tracker's job is done — follow the processo regulatório through /regulatory-legal:reg-feed-watcher.

US-agency fallback (gated)

Use this ONLY when the tracked item is a US federal rulemaking (an agency Notice of Proposed Rulemaking / NPRM) rather than a Brazilian consulta pública or tomada de subsídios — e.g., the practice profile's jurisdiction footprint includes the US and a US regulator (SEC, FTC, CFPB, etc.) has opened a comment period. Do not apply this to Brazilian agency processes.

When it applies, the mechanics differ:

• The instrument is an NPRM published in the Federal Register; comments are filed on Regulations.gov against the rule's docket within the published comment period. [model knowledge — verify]
• Everything else in this skill (the tracker, the deadline reminders, the consequential-action gate, the not-filing/waived logging) works the same — only the underlying regime label and filing portal change. Tag any US cite [model knowledge — verify] and confirm against Regulations.gov before relying.

The comment-decision gap_type semantics, the per-send Slack confirmation rule, and the comment-tracker.yaml schema live in the gap-surfacer reference skill — load it before doing substantive work.