Governance & Exam Readiness

Would your RIA’s AI use survive an SEC or state exam? A deterministic self-assessment across the six exam-surface domains an examiner probes when a firm uses AI — AI in marketing (20, fatal), books & records for AI outputs (20, fatal), supervision & written policies (18, fatal), vendor AI oversight (16), client disclosure & Form ADV (14), AI communications capture (12) — marked 0/1/2 on your own evidence for a 0-100 score banded EXAM-READY / OPEN FINDINGS / NOT DEFENSIBLE. A dispositive fatal-domain gate forces NOT DEFENSIBLE when any of the three fatal domains is zero, because each draws a deficiency letter on its own — so a firm can score 73 and still be NOT DEFENSIBLE with books-and-records at zero. Portfolio rolls up to the worst branch (ALL EXAM-READY / FINDINGS TO CLOSE / DEFICIENCY LIKELY) with the domain to fix first. Date-agnostic and people-blind. Runnable Python engine + workbook + assessment & remediation playbooks + a 5-firm sample. Grades a firm’s evidence file, renders no legal ruling, scores no person. Not legal advice.

Seventy percent of RIAs run an AI meeting notetaker and regulators treat an ungoverned one like an unauthorized texting app. This tripwire grades each tool/deployment on six weighted controls — client consent before capture and human review before notes enter the record are FATAL — for a 0-100 score and DEFENSIBLE / GAPS / NOT DEFENSIBLE per tool, with a worsen-only gate: either fatal control at zero forces NOT DEFENSIBLE no matter the score. The firm rolls up to its worst tool (ALL DEFENSIBLE / GAPS TO CLOSE / STOP AND FIX). Runnable Python engine + workbook + audit & remediation playbooks + a 5-tool sample. Grades the process, never a person; renders no legal ruling and takes no position on whether AI summaries are books-and-records. Not legal advice.

Grade every testimonial, endorsement, and paid promoter under SEC Marketing Rule 206(4)-1. Mark each arrangement on six weighted controls — required disclosures clear & prominent (FATAL) and a written promoter agreement (FATAL only for a compensated, over-de-minimis, non-affiliate promoter) plus compensation/conflicts disclosed, bad-actor screen, claims substantiated/net shown, and ad-copy recordkeeping — for a 0-100 score and COMPLIANT / GAPS / NON-COMPLIANT per arrangement. A conditional worsen-only gate fires exactly where the rule requires it, so an identically-marked de-minimis twin stays COMPLIANT while the compensated one fails. Campaign rolls up to its worst arrangement (ALL COMPLIANT / GAPS TO FIX / PULL OR FIX). Runnable Python engine + workbook + audit & remediation playbooks + a 6-arrangement sample. Grades the arrangement, never a person; renders no legal ruling and confirms no compliance status. Not legal advice.