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Practical guides on AI use documentation, disclosure obligations, and defensibility.
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The RIA AI-Use Audit Checklist
A practical checklist for documenting your AI use as an investment adviser. It’s a record-keeping aid informed by published SEC and FINRA guidance — not a statement that any field is required by a regulator. Use what fits your practice.
Before you use AI for client work
- ☐You have a written AI-use policy (even a one-pager) that says which tools are permitted and for what.
- ☐You know which uses create a record worth keeping: anything that informs a recommendation, a client communication, or an analysis you act on.
While you use AI
- ☐The prompt and the response are captured together — not just the output.
- ☐The tool, the date, and (where it matters) the client/matter are recorded.
- ☐You can tell later which version of which model produced what.
Retention
- ☐AI-related records are kept on the same five-year clock as the advice they support (Rule 204-2).
- ☐Records are stored so they can’t be silently altered after the fact — and so you can produce them on request.
When an examiner asks
- ☐You can show what you asked, what the AI returned, and when.
- ☐You can demonstrate the record wasn’t edited after it was created.
- ☐You can hand over a copy that the examiner can verify independently.
AuditTrail automates the capture, sealing, and export steps above across ChatGPT, Claude, and Gemini. This checklist is a recordkeeping aid, not legal advice, and does not certify compliance with any regulation.
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