Question 1

What does the Advisory-Firm AI Exam Defensibility Audit actually grade?

Accepted Answer

It grades the six surfaces an SEC or state examiner probes when an investment adviser uses AI: how AI shows up in your marketing, whether AI outputs are kept as records, whether your compliance program covers AI, how you oversee AI vendors, whether AI use is disclosed on Form ADV, and whether AI-assisted client communications are captured. You mark each domain 0/1/2 on the evidence you could actually produce, and the audit returns a defensibility verdict per firm or branch — EXAM-READY, OPEN FINDINGS, or NOT DEFENSIBLE. It grades your evidence file, not the AI itself, and never scores a person. It is not legal advice.

Question 2

Why can a firm score 73 and still read NOT DEFENSIBLE?

Accepted Answer

Because three of the six domains are fatal, and a zero on any one of them forces NOT DEFENSIBLE regardless of the total. Marketing, books-and-records, and supervision are the load-bearing controls — each is a finding that reliably draws a deficiency letter on its own, so a strong file elsewhere can't cure a total absence of one. In the worked example the Northgate branch scores 73 on points yet reads NOT DEFENSIBLE because its books-and-records domain is zero: its AI notetaker summaries are retained nowhere. Set that domain to 1 and it clears. A high score can hide a fatal hole; the gate exists so it can't.

Question 3

How is this different from the 'Pass a 90-Day AI Audit?' Readiness Triage?

Accepted Answer

The 90-Day Readiness Triage is a generic, cross-industry front door that scores seven governance domains for any organization. This audit is built specifically for investment advisers and the examination they actually face: its six domains map to the Advisers Act frame — the Marketing Rule, books-and-records under Rule 204-2, the compliance program under Rule 206(4)-7, Form ADV disclosure — and its fatal gates are the findings that draw an adviser a deficiency letter. Use the Triage to find which broad governance gap to close first; use this when the exam in question is an adviser exam about your AI use.

Question 4

Where do the rules and dates live — is the tool tied to a specific regulation?

Accepted Answer

The engine is deliberately date-agnostic and rule-neutral: it grades your process and evidence, encodes no statutory date, and renders no legal ruling, so it doesn't break when a rule or its timeline shifts. The specific planning references — the Investment Advisers Act, Marketing Rule 206(4)-1, books-and-records Rule 204-2, compliance Rule 206(4)-7, and Form ADV — are named in the playbooks as context only, not as legal conclusions. Which rules apply to your firm, and every date, must be confirmed with your CCO or a qualified securities attorney. This is a readiness aid, not legal advice.

Question 5

What's in the download?

Accepted Answer

A workbook and a runnable engine that produce the same verdict. The .xlsx has three tabs — Start Here, Dashboard (portfolio verdict, counts, and the domain to fix first, with a fixed evaluation date), and Exam Audit (a row per firm or branch with live weighted scoring and the fatal-domain gate). Two playbooks cover marking the six domains the way an examiner reads them and closing the fatal gaps first, with the concrete evidence to assemble for each. A zero-dependency Python engine grades a firms file from the command line and outputs the same verdict. Everything is deterministic and offline — it opens in Excel, Google Sheets, or Numbers and connects to nothing.

Question 6

Is this a compliance audit or legal advice?

Accepted Answer

No. It is a readiness self-assessment that grades a firm's evidence file from your own marks — not a compliance audit, a mock exam conducted by a regulator, a certification, or an opinion of counsel. It confirms no regulatory obligation, renders no legal ruling, connects to nothing, files nothing, and scores no person. Treat the verdict as a structured way to find your fatal exam gaps before an examiner does, and confirm which rules apply to your firm — and every date — with a qualified compliance or securities attorney. Not legal advice.

Your AI use is on theexam surface now.

Examiners stopped treating AI as a novelty. The controls it needs are the ones you already owe.

AI is in your marketing

AI outputs are records — or should be

A high score can hide a fatal hole

Mark six domains per firm. The fatal gate does the rest.

The same verdict from the command line.

Six weighted domains, three of them fatal.

AI in marketing

Books & records for AI

Supervision & policies

Vendor AI oversight

Disclosure & Form ADV

AI comms capture

A way to find your fatal exam gaps before an examiner does. Not an opinion of counsel.

What it is

What it isn't

Anyone who owns an adviser's exam readiness.

RIA principals & CCOs

Compliance consultants

Multi-branch & roll-up firms

Firms adopting AI notetakers

Triage the broad gap; deepen the domains this audit flags.

Pass a 90-Day AI Audit? Readiness Triage

AI Output Audit-Trail & Record-Keeping Kit

AI Vendor & Sub-Processor Data-Flow Register

Before you buy.

Find the fatal gap first.
Before the examiner does.