// SUPERVISION · COMMUNICATIONS · RECORDS · VENDORS

Two rulebooks, one firm, and eight things you are already doing.

A broker-dealer answers to the SEC, to FINRA and to the states. An adviser answers to the SEC or to the states, depending on where it registered. Plenty of firms hold both, and the same piece of software has to answer to each on its own terms. This is a read on where AI actually touches supervision — and what evidence has to exist before someone asks for it.

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Workflows covered in the guide:

  • Say which of your two rulebooks a given AI use actually answers to.
  • See why review capacity, not drafting capacity, is the marketing risk.
  • Ask what went into the tool, not only what came out of it.

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// the problem

The policy and the artefacts behind it do not match.

The approved-tool list, the review evidence, the retention decision and who made it, the record of the last model change, the accept rate on anything a human is supposed to be deciding — most firms discover the gap between the policy and the artefacts during an examination rather than before one. The obligations did not change when AI arrived. The volume flowing through them did, and the processes were sized for a different throughput.

// what you’ve tried

And the policy was written before any of this arrived.

Wrote an AI policy, and discovered no one could say which tools it covered

Approved one tool, then found the work had already moved to three others

Asked the vendor what changed in the model, and got a release note about the interface

None of those failed because someone was careless. They failed because supervision was designed around a process that has since changed shape underneath it — more output, produced faster, travelling to more places than the procedures were written to cover.

// what changes

Here’s what the guide covers.

p. 3

Say which of your two rulebooks a given AI use actually answers to.

from “Two rulebooks, one firm”
p. 4

See why review capacity, not drafting capacity, is the marketing risk.

from “Marketing and social content”
p. 5

Ask what went into the tool, not only what came out of it.

from “Client communications”
p. 6

Decide what a meeting summary is before a default setting decides it.

from “Meeting notes and summaries”
p. 9

Tell whether your human-in-the-loop is a control or a formality.

from “Advice support and next best action”
p. 10

Treat a model change as a supervision event, and negotiate the notice.

from “Vendors, models and change”

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Choose a workflow you can put to use.

Start with one task and the matching chapter. Gather the inputs, try the example, and check the result against your requirements. The guide is a reference for that process. Your tools, access and experience determine what is practical for you.

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// inside the guide

Where AI actually touches supervision, under both rulebooks.

Eight things advisory firms and broker-dealers are already doing with AI, each marked on the FINRA side and the Advisers Act side, with the control that makes it defensible and the person who has to sign it. It names rule areas and quotes no rule text — deliberately, because regulation moves and a consultant reciting it from memory gives your CCO something to fact-check rather than something to use.

01

Why the same activity answers to two different rulebooks

02

Where AI genuinely changes supervision, and where it changes nothing

03

What evidence has to exist before an examiner asks for it

04

The five controls that recur under every use case

11 chapters
Two rulebooks, one firmMarketing and social contentClaims a firm makes about its own AIClient communicationsMeeting notes and summariesResearch and internal analysisSurveillance and reviewAdvice support and next best actionVendors, models and changeThe five controls that keep recurringWhat would you have to show?
// how it works

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// before you ask

A few fair questions.

What should I check before using the guide?

Read the chapter list and examples to see whether the guide fits your task. The documents describe a June 2026 snapshot. Product features, access and pricing can change, so confirm any setup instructions against current vendor documentation.

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Find out what you could actually put on the table.

Eight things firms already do with AI, and what each one touches under both rulebooks. Names rule areas, quotes no rule text, and is not legal advice. Free, takes a second, yours to keep.

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An independent guide from Prometheus Consulting, for ccos, principals and ria leadership at supervised firms. Downloadable guide snapshot: June 2026. Landing page revised 2026-10-14. Check product instructions against current vendor documentation. Unofficial: product names are trademarks of their respective owners, none of whom reviewed or endorsed this guide.