Beat 5 · Governed by Construction
Human approval is the default everywhere. The controls explain how we keep it that way.
Can the AI give advice or trade on its own?
No. Human-in-the-loop is the default everywhere. Autonomy is earned per workflow, through measured evaluations — never assumed. Client-facing work always carries a named human approver — the author of record — on a tamper-evident audit trail.
What about hallucinations in client communications?
Outputs are grounded and cited in your own data, reviewed and approved by a human (the author of record), and screened by automated evals for unsupported claims, Marketing-Rule issues, and data leakage before reaching a person.
Is our client data used to train AI models?
No. Inference runs through enterprise channels under contractual no-training and retention limits, in-region. There is no fine-tuning on your data.
How is NPI handled?
Classified at ingestion, minimized (we take only what a workflow needs), encrypted in transit and at rest, and sensitive identifiers redacted before anything leaves your boundary.
How is data encrypted?
TLS in transit; KMS-backed encryption at rest with per-firm keys — which also enable clean, verifiable deletion (crypto-shredding) on exit.
Is our firm isolated from your other clients?
Yes — structurally. Each firm gets its own isolated data store, vector namespace, and keys, resolved from a signed identity context, not a query filter that could be forgotten. "Cross-tenant data bleed" is a first-class, automatically tested failure mode that gates every release.
How do you support our regulatory obligations?
Controls are mapped to specific rules: Books & Records (204-2) → immutable, exportable audit trail; Marketing Rule (206(4)-1) → human-approved, screened client content with records retained; Reg S-P (incl. 2024 amendments) → safeguards, incident response, and breach notification within your ≤30-day window. The FINRA 17a-4 WORM module is available for hybrid RIA/BD firms.
What is the obligation overlay?
It is a machine-readable map of your compliance obligations, each tied to its evidence. The overlay is a mirror for review and exam preparation; it is not prompt content and it is not legal advice.
How is this verified?
Verification is the culture: ~30 verification gates / 200+ automated checks as of July 2026, including adversarial scenarios and clean-day negative controls.
Are we still the record-holder?
Yes. Your authoritative books and records stay in your existing, already-compliant systems by default; the twin is a derived layer. You can export everything at any time.
Who can access our data, and what about sub-processors?
Vendor access is least-privilege, time-bound, and audited; staff federate to your identity provider with MFA. We maintain a disclosed sub-processor list (cloud + model provider) with no-training/retention flow-downs, and a written information-security program. We are building toward SOC 2 Type II covering the data plane, gateway, audit store, and key management.
Business continuity & incident response?
Multi-AZ redundancy, tested backups, and a documented DR runbook; an incident-response process notifies you fast enough to meet your customer-notification duty. The platform is documented as a dependency in your BCP.
What happens to our data if we leave?
No lock-in. Full export in open formats (canonical data, documents, twin-generated records, audit trail), then verified deletion. Because your authoritative records live in your own systems throughout, leaving never puts your books and records at risk.
Due diligence
We'll provide a point-by-point answer key for your CCO.