AI Policy Template for Financial Advisory Firms
Financial firms operate under supervision and recordkeeping rules that don't pause when an AI drafts the message. The SEC and FINRA have both signaled that AI-assisted client communications, recommendations, and marketing are subject to the same review requirements as human work — and that firms should have written AI policies. This generator produces one tuned to GLBA data restrictions and supervisory review requirements.
Generate a policy customized for financial advisory firms in about 3 minutes:
Generate an AI policy for financial advisory firmsFree preview · $49 one-time to download
AI risks specific to financial advisory firms
- Client communications drafted by AI are still subject to FINRA supervision and recordkeeping rules
- Nonpublic personal information entered into AI tools can violate GLBA safeguards
- AI-generated market commentary can include fabricated statistics or stale data
- Regulators (SEC, FINRA) have flagged 'AI washing' and unsupervised AI use in exams
Compliance requirements your policy must address
GLBA
Nonpublic personal information (NPI) covered by the Gramm-Leach-Bliley Act — including account numbers, balances, credit information, and any data collected in connection with providing a financial product — must not be entered into AI tools that have not been approved for NPI under the Company's GLBA safeguards program.
FINRA / SEC
Client communications, investment recommendations, and marketing materials produced with AI assistance are subject to the same supervision, review, and books-and-records requirements as human-authored content under FINRA and SEC rules. AI-assisted recommendations must be reviewed by a registered principal before use.
SOX
AI tools must not be used to prepare, alter, or summarize financial records subject to Sarbanes-Oxley internal controls unless the output is fully reviewed under the Company's existing financial review and sign-off process. AI use never reduces the documentation or approval requirements of an internal control.
What a complete AI policy for financial advisory firms includes
- Purpose, scope, and who the policy covers (employees, contractors, volunteers)
- Approved AI tools and the process for approving new ones
- Acceptable uses — and the prohibited list, including data that must never enter prompts
- Privacy-law clauses for your jurisdictions (GDPR, EU AI Act, CCPA, PIPEDA) plus GLBA and FINRA / SEC and SOX requirements
- Human review and accountability rules for AI output
- Incident reporting, enforcement, and annual review
Frequently asked questions
- Can advisors use AI to draft client emails?
- Generally yes, if the firm's normal communication review process applies and no nonpublic client information enters unapproved tools. The policy should make both conditions explicit.
- Does this cover SEC/FINRA expectations?
- The generated policy includes supervisory review requirements for AI-assisted client communications and recommendations. Your compliance officer should adapt the review workflow to your existing WSPs.
Get your AI policy for financial advisory firms
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Start the generatorDraftAIPolicy is not a law firm; documents are self-help templates, not legal advice.