Tez I Solutions

Industries · Financial advisory firms

How we handle your clients’ data

Your CRM is full of prospects nobody followed up — and every record in it is regulated. An outside vendor touching that list is the first thing your examiner will ask about.

Applies to
Broker-dealers, SEC- and state-registered investment advisers, dual registrants
Covers
Lead reactivation and AI services
Current as of
October 2026 · V2
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Part 1

Lead reactivation

How your list is checked, ranked and worked — what leaves your side, what never does, and the rules your industry adds.

What we take, where it goes, and who sees it.

For compliance, operations and principals

Lead reactivation works the prospects your firm has already generated — people who asked about your services, were followed up once or twice, and then were not. We rank them by likelihood to book a conversation and work the list from the top, so your advisors spend their time on the people most likely to sit down with them.

Every one of those records is regulated: by Regulation S-P, by your supervisory and recordkeeping rules, and by federal and state telemarketing law. This document sets out, control by control, how the engagement keeps your firm inside those rules — and which decisions stay with your firm. It is written to be read by your Chief Compliance Officer and filed with your vendor due diligence.

Sections 02 to 06 are the plain-English part. They show the whole system in pictures, explain the four things the ranking looks at, and follow one example lead from your CRM to your advisor’s desk. The sections after them are the detail your compliance team will check.

01

Commitments

Ten commitments, before the detail

  • 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails, addresses and account numbers stay in a secure environment. The AI provider sees a random ID and a few short facts, nothing more.
  • 02 · Nothing goes out without your approval — Your principal or CCO approves every template before use. Our review sits on top of yours, never in place of it.
  • 03 · Every message lands in your archive — Outreach goes through your archived channels, or is captured into your archive as it is sent. Nothing off-channel.
  • 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending. Opt-outs are permanent.
  • 05 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment without your written instruction.
  • 06 · Breach notice within 72 hours — As soon as possible and no later than 72 hours — the window Regulation S-P requires your firm to put in our contract.
  • 07 · Return and destruction, certified — At the end of the engagement your data, including the identity key, is returned or destroyed, and we confirm it in writing.
  • 08 · No investment advice — Messages invite a conversation with your advisor. No recommendations, performance figures, projections or testimonials.
  • 09 · A fee structure your compliance team chooses — A flat fee or a results-based fee, with how each is treated under your rules set out in section 14.
  • 10 · Evidence on request — Every control here has something you can inspect. We complete your due diligence questionnaire during onboarding.

02

The whole picture

The system on one page

The system works in three zones. Names and contact details stay on your side. Our scoring works only with a random ID and a few short facts. The results come back to your side, where your firm approves and sends.

Three zones: your firm keeps identity, Tez scoring sees random IDs and facts, results return to your firm YOUR FIRM · NAMES AND CONTACT DETAILS STAY HERE G2  Check the list Opt-outs, Do Not Call Swap names for IDs The key stays with you G3  Notes into facts Answers from a fixed list TEZ SCORING · RANDOM IDS AND FACTS ONLY Score and rank Four factors, plain arithmetic G4  Explain A reason and a short summary Pick the next step Channel and timing YOUR FIRM · RESULTS LAND HERE Match back ID to your CRM record G5  Your approval Principal or CCO signs off G6  Send Through your archive Outcomes (booked, held, signed) come back by random ID and improve your firm’s ranking only. G1  The agreement and intake review clear before any data moves. G7  Retention and destruction.

G1 — the agreement and intake review — clears before any data moves. G7 covers retention and destruction.

Dashed gold-edged boxes, marked G1 to G7, are compliance gates. Nothing passes a gate until it clears. Section 03 lists what each one checks.

03

Step by step

From our first conversation to the first message

Seventeen steps in five phases. The gate marks show where a compliance check has to clear before the work moves on.

Onboard (before any data)

  • 01 First conversation — How your firm works with prospects today
  • 02 Agreement — Roles, purpose, subprocessors, 72-hour notice G1
  • 03 Intake review — Lead sources, consent wording, opt-outs G1
  • 04 Secure environment — In your environment, or our workstation

Prepare (on your side)

  • 05 Map your stages — Your CRM statuses to eight shared stages
  • 06 Check the list — Opt-outs, Do Not Call, clients, complaints G2
  • 07 Swap names for IDs — A random ID; the key stays with you
  • 08 Notes into facts — Fixed-list answers; figures become tiers G3

Rank (Tez scoring)

  • 09 Score — Intent, Opening, Reachability, Fit
  • 10 Tier and reasons — A to D, with the top reasons
  • 11 Short summary — Why call, and an opening line, checked G4
  • 12 Next step — Channel by consent, and timing

Act (on your side)

  • 13 Match back — The ranked list appears in your CRM
  • 14 Your approval — Principal or CCO approves the wording G5
  • 15 Send — Re-checked at sending; through your archive G6

Learn (ongoing)

  • 16 Record outcomes — Booked, held, signed; a held-back group
  • 17 Improve and report — Your ranking only; results you can check G7
GateWhenWhat has to be true to passWho decides
G1Before any dataSigned agreement; your lead sources, consent wording and opt-out records reviewed; your registration type and fee model confirmedYour firm and Tez
G2As the list arrivesOpt-outs, Do Not Call, existing clients, complaints and anyone hostile are set aside and never rankedSoftware, on your rules
G3Before anything leaves your sideOnly approved facts cross: no names, contact details, notes, exact figures or exact datesSoftware, checked by Tez
G4After a summary is draftedNo personal data, no banned topics, nothing the facts do not supportSoftware, then your advisor
G5Before any outreachYour principal or CCO approves the wording and the batchYour firm
G6At the moment of sendingConsent for that channel, Do Not Call, quiet hours in the lead’s time zone, opt-outsSoftware, on your channels
G7Throughout, and at the endOutcomes kept by random ID, used for your firm only, returned or destroyed at terminationTez, certified to you

04

The ranking

How the list is put in order

Every lead is checked first, then looked at through four factors. The factors combine into one score, and the list is sorted by it. The sorting is plain arithmetic, not an AI model, so every score can be explained in a sentence.

Leads pass a gate, are scored on four factors, and produce an order, a reason and a next step G2  Checked first Opt-outs, Do Not Call, current clients Set aside Never ranked or contacted THE FOUR FACTORS · BUILT FOR EVERY LEAD Intent How far they got, and how recently Opening Why they paused, and what has changed Reachability Can we reach them, with consent Fit Can your firm still serve them Score and rank Plain arithmetic, no AI model Value tier Optional, your call Order and tier A to D, best first Why this lead Top reasons, in one line Next step Channel, timing, angle
FactorThe question it answersWhat it looks at, for an advisory firm
IntentHow serious were they, and how long ago?How far they got: inquiry, intro call, discovery meeting, plan presented. Time since the last real conversation. Whether they replied before. How many follow-ups have already been tried.
OpeningIs there a real reason to get back in touch?The reason they paused: timing, a spouse, fees, another firm. A condition they named, such as “after the business sale closes.” Whether that moment has now passed.
ReachabilityCan we reach them, and are we allowed to?A working email or phone. Consent on file for each channel. Do Not Call status, and whether the three-month inquiry window has passed.
FitCan your firm still serve them?A state you are registered in. Whether they meet your account minimum, as a yes or no only. Whether they want a service your advisors offer.

How the ranking gets better

  • 01It starts from your team’s experience — Your advisors tell us how often each kind of paused prospect comes back. Those estimates set the first odds. Until your results come in, the scores are educated estimates, and we say so.
  • 02It corrects itself from your results — As meetings are booked, held or declined, the odds for each reason move toward what actually happened at your firm.
  • 03It becomes a model of your firm alone — After about 300 recorded outcomes, the ranking is fitted to your firm’s results. It is never trained on, or pooled with, another firm’s data.
  • 04A held-back group keeps us honest — With your agreement, about one lead in ten is held back and not contacted for a set period. Comparing the two groups shows what the outreach actually changed, rather than what would have happened anyway.

05

A worked example

One lead, from your CRM to your advisor

Karen Mills is fictional. Her record is shaped like a real one. Follow it through the four cards, left to right and top to bottom.

1 · Your CRM record (stays with you)

FieldValueNote
nameKaren Millskey table
phone(713) 555-0148key table
emailkaren.m@example.comkey table
CRM ID0035e00000Qx7key table
statusNeed to think about itbecomes a stage
noteWants to wait until her 401(k) rollover clears in Marchbecomes facts
assets$412,000becomes a tier
last contactMarch 14, 2026becomes days

2 · What we receive (leaves your side)

FieldValueNote
IDs_7Qx9mK2arandom
stagePlan presentedIntent
days since203Intent
reasonTimingOpening
conditionYes, waiting on an eventOpening
reachEmail yes · text no consentReachability
fitRegistered state yes · minimum yesFit
value tier2 of 3, only if you opt inoptional

Never leaves your side: her name, phone, email, CRM ID, the note itself, the asset figure, exact dates.

3 · What comes back (back to you)

FieldValueNote
IDs_7Qx9mK2a
score71 · tier A
reasons+ named a condition · + plan presented · − 203 days since contact
reason linePlan presented; paused for an event that should have passed.fixed wording
summaryShe paused until something she was waiting on cleared in March. That has likely passed. A good opener is to ask whether it went through.AI, checked
next stepEmail, Tuesday afternoon her time

4 · In your CRM (stays with you)

FieldValueNote
recordKaren Mills · tier A · 71matched back
fieldsReason line, summary and next step added to her record
draft“Hi {first_name}, …” with her name filled in only at sendingplaceholder
flagsText blocked, no consent · Do Not Call check requiredG6

No text consent on file, so the next step is email. Her inquiry is over three months old, so a Do Not Call check comes before any call. Her advisor sees her name here, in your own CRM, for the first time.

  • 01Her note became a few facts — “401(k) rollover” left only as “waiting on an event.” If your CCO approves a short list of event types, the summary can be more specific without the note ever leaving.

06

The suggestion

How the “why call” note is written and checked

Each lead comes back with a reason line in fixed wording and a short summary drafted by an AI model, both written only from the facts in card 2 of section 05. The AI writes; it does not decide. The order comes from arithmetic, and your firm approves anything sent.

Facts feed a fixed-wording reason line and an AI draft; both pass a check before an advisor sees them, then approval and sending The facts and reasons Random ID, no names or figures Your rules Script, never-say list Reason line Fixed wording, filled from the facts AI draft Short summary and an opening line G4  Checked before anyone sees it Personal data, banned topics, made-up facts Passes Goes to your advisor, in your CRM Fails Reason line only, flagged for review G5 + G6  Approve, then send Your sign-off; checks at sending

The four checks at gate G4

  • No personal data — The draft may not contain a name, number, email or address. Names appear only as a placeholder, filled in on your side at sending.
  • No advice, no promises — No recommendations, performance figures, projections, rates or guarantees. The draft invites a conversation with your advisor, nothing more.
  • Nothing made up — Every statement in the summary must trace back to one of the facts it was given. A statement that does not is treated as a failure.
  • Your never-say list — Phrases and topics your firm rules out are blocked, on top of the general rules above.

07

Roles

Your firm stays the covered institution

Under Regulation S-P your firm is the covered institution and Tez I Solutions is a service provider. You share consumer information with us under the service-provider exception (17 CFR 248.13), on a contract that limits our use of it to this engagement; the reuse and redisclosure limits in 248.11 then bind us. Prospects who asked about your services but never opened an account are consumers under the rule, so the dormant list is covered in full. Since the 2024 amendments, your incident response program must include written oversight of service providers. This is how responsibility divides.

ObligationYour firmTez I Solutions
Privacy notices and opt-outsOwnsHonours your suppression and opt-out lists
Approval of communicationsPrincipal or CCO approves before useSubmits templates; never alters approved wording
SupervisionOwns, under FINRA Rule 3110 or your compliance programKeeps the draft, approved version and approver for every template
Books and recordsOwns the archiveSends only through it, or captures into it
How leads were obtainedWarrants it in the agreementRecords the consent source and enforces it at send time
Security of data we holdOverseesOperates the controls in sections 10 and 11
Breach notice to customersOwns, within 30 daysNotifies you within 72 hours and supports the investigation
Vendor due diligencePerforms and documentsCompletes questionnaires and supplies evidence
Access and deletion requestsReceives and instructsExecutes within your deadline and confirms
Return or destructionInstructsExecutes and certifies in writing

08

Data

What we take, and what we never take

The least data that lets the list be ranked and worked. Where a figure carries signal, we keep a tier and drop the figure.

DataHow it is handledReaches the AI model
Name, phone, email, postal addressHeld only in the encrypted key table on your side; used to address a message when it is sent.No
Account numbers, SSN, date of birth, tax and government IDsExcluded from the export. If one appears in a note, the record is quarantined and the value removed.No
Assets, account values, income, net worthOnly if your compliance team agrees: turned into a three-level tier on your side, used for ranking. An account minimum becomes a yes or no. The figure never leaves.No
Inquiry and contact datesConverted to intervals — “14 months since last contact.”Interval only
Lead source, stage, status, advisorKept as categories; advisor names replaced with codes.As categories
Call and relationship notesRead on your side and turned into fixed-list answers (section 09). The note itself never leaves.Fixed-list answers only
Consent records and opt-outsKept as an append-only history and enforced at send time.No
Holdings, transactions, custodian data; age, gender, ethnicity, healthNot requested, not used to rank, not sent.No

09

The privacy layer

Where AI sits, and what it sees

StationWhat happensHolds or sees
01 · Your firm — Your CRMFull records stay here. Only the agreed fields are read.Holds: everything, as today
02 · Secure env. — Separation, and notes into factsA local model with no outside connection answers fixed questions about each note. The key lives only here.Holds: identifiers, key table, notes
03 · Tez scoring — Ranking, then a short summaryRanking is arithmetic in our own code. Anthropic’s Claude words a summary from the facts.Sees: random ID, fixed-list facts
04 · Your channels — Approved, then sentNames filled in on your side; consent checked; sent through your archive.Holds: the message, as a firm record

Notes are the most sensitive part of a record and the most useful. So they are read where they already are, and only short answers leave. Five layers make sure of it.

LayerWhat it does
1 · Field allow-listOnly approved columns are read. Structured identifiers are separated by rule, not by a model’s judgement.
2 · Identifiers stripped firstPhone numbers, emails, account and card numbers, Social Security numbers, dollar amounts and dates are removed from a note before the local model reads it.
3 · Fixed questions, fixed answersThe local model answers set questions — why they paused, whether they named a condition, which kind of event — by choosing from a list your CCO has seen. It cannot write free text.
4 · Unsure means a person decidesAn answer the model is not confident about is not guessed. The record is held for a person to review. The process fails closed.
5 · Final scanEvery record is scanned again before it leaves. A record carrying anything outside the approved fields is held back, not sent.

10

Where it runs

Two ways to run the secure environment

The secure environment is where identifiable data lives during the engagement, and your firm chooses where it sits. In both options the key table never leaves it, and the AI provider receives only a random ID and fixed-list facts.

Inside your environmentOn a Tez-operated workstation
Where raw data sitsYour infrastructure; it never leaves your perimeterAn encrypted workstation operated by Tez, in a separate encrypted volume per firm
AccessYou control it. We use a named, least-privilege account you can revoke at any timeOne named individual, with multi-factor authentication
NetworkYour controlsOutbound limited to the AI provider and your sending channels
LoggingYour logging stackAccess log kept for the engagement, provided on request
SuitsFirms with an IT team or managed IT providerFirms without capacity to host it

Workstation standard, when Tez operates it

  • Encrypted at rest — Full-disk encryption, plus a separate encrypted volume for each firm’s data.
  • Dedicated and locked down — An OS account used only for client data, multi-factor sign-in, screen lock, current patches, endpoint protection.
  • No cloud sync — Client data is never stored in a synced folder or consumer cloud backup, and is excluded from sync by configuration.
  • Wiped at the end — The firm’s volume is destroyed at termination and the destruction certified in writing.

11

Security and incidents

The controls, and what happens if one fails

ControlEvidence you can ask for
Written information security program, modelled on Massachusetts 201 CMR 17.00The program document
Encryption in transit and at restConfiguration record
Multi-factor authentication on every account that touches your dataAccount inventory
Access limited to named individuals, reviewed quarterlyAccess list and review log
Access to your data loggedLog extract
Background check for anyone with access, on your requestWritten confirmation
Raw data held only for the life of the engagementRetention schedule
Return or destruction within 30 days of terminationSigned certificate
Cyber liability insurance, where your contract requires itCertificate of insurance
Written incident response plan, reviewed each yearThe plan and its last review

If something goes wrong

  • 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
  • 02 · Notify you within 72 hours at the latest — Which records and fields, what window, what we have done. Updates follow as we investigate.
  • 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation.
  • 04 · Support your notice, never pre-empt it — Customer notice is your firm’s decision, within 30 days under Regulation S-P. We never contact your customers about it.

12

Supervision and records

Your supervisory system covers this work

Outsourcing does not outsource responsibility (FINRA Notice 21-29), and an AI-drafted message is still your firm’s communication (Notice 24-09). With the SEC’s AI proposal withdrawn as of June 17, 2025, these existing rules are the standard.

  • 01Broker-dealers — FINRA Rule 2210 — A template used with more than 25 retail investors in 30 days is a retail communication, approved by your registered principal before use. Individual replies are correspondence, reviewed under your Rule 3110(b) procedures.
  • 02Investment advisers — the Marketing Rule — Outreach offering your services may be an advertisement under Rule 206(4)-1; your CCO classifies and approves each template before use.
  • 03Content limits — No performance figures, projections, testimonials, guarantees or product recommendations — only a fair, balanced invitation to talk to an advisor.
  • 04Every message is a firm record — Exchange Act Rule 17a-4 and FINRA Rule 4511; Advisers Act Rule 204-2. Every message, outbound and inbound, goes through or is captured into the archive you already use.
  • 05An approval trail you can produce — For every template: the AI draft, the approved wording, who approved it and when.
  • 06Rails the drafting stops at — Identity, account specifics, complaints and anything that reads as advice go to your advisor. Outreach never asks a lead to confirm personal or account details (Regulation S-ID). Every AI draft passes gate G4 before your principal sees it (section 06).

13

Consent

No evidenced consent, no text message

Under the Telephone Consumer Protection Act the party that sends a message can be liable for it directly. So consent is enforced in software at the moment of sending, not left to policy.

  • 01 · A consent history, not a checkbox — Each lead’s consent is an append-only record of source, wording, channel and date. Contactability is derived from it, never overwritten.
  • 02 · Checked when the message sends — Consent, suppression, Do Not Call and quiet hours are rechecked at sending, not at list-building. Yesterday’s opt-out holds today.
  • 03 · Aged leads without evidenced consent — Email, or your advisors directly — not text. An inquiry over three months old is no established business relationship for Do Not Call.
  • 04 · Do Not Call and reassigned numbers — Checked against the National Do Not Call Registry and the FCC Reassigned Numbers Database. Results dated and stored.
  • 05 · Quiet hours and state law — 8am to 9pm in the lead’s local time, narrower where required. Florida, Oklahoma, Maryland, Washington and Texas SB 140 rules applied by state.
  • 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your advisor is honoured on every channel and survives any re-import. Email unsubscribes within 10 business days.

14

How we are paid

Two fee models, and how each is treated

We offer two models. Fees are set in conversation and are not in this document. What belongs here is how each model is treated under the rules that apply to your firm, so your compliance team can choose with that in view.

Model A: Flat monthly fee

A fixed fee for operating the service. It does not depend on accounts opened, assets brought in or transactions.

  • Broker-dealers. The payment is not transaction-based, which supports your firm’s determination under FINRA Rule 2040.
  • Investment advisers. We operate your outreach rather than endorse your firm, and the fee is not paid per client referred.
  • The simplest model to approve, document and supervise.

Model B: Results-based fee

A share of revenue attributed to reactivated leads, measured from your CRM’s own records.

  • Broker-dealers. A fee that depends on accounts or transactions is transaction-based. FINRA Rule 2040 and Exchange Act section 15(a) bar paying it to an unregistered person whose activity requires registration. Tez I Solutions is not a registered broker-dealer.
  • Investment advisers. A fee per new client or a revenue share is likely a compensated promoter arrangement under Rule 206(4)-1: written agreement, disclosure and oversight, and state solicitor rules may apply.
  • Offered only where your compliance team and counsel approve the structure in writing.

15

Subprocessors and contract

Who else touches the data, and what we sign

SubprocessorWhat it holdsWhen
Anthropic (Claude API)A random ID and fixed-list facts only. No names, contact details, notes or exact figures. Not used for training by default under Anthropic’s commercial terms; zero data retention requested where offered; can run through your own cloud provider insteadEvery engagement
Your archiving and messaging providersMessages, as they do todayEvery engagement, under your contracts
Messaging provider operated by TezPhone numbers and message contentOnly if you do not send through your own texting channel, and only with real-time capture into your archive
Operator console hostingNamed in your agreement, with what it holdsWhere your team uses our console

The full list is an exhibit to your agreement. We give 30 days’ notice before adding or changing a subprocessor.

What the agreement contains

  • Roles and purpose — Your firm as covered institution, Tez as service provider; use limited to this engagement, as Regulation S-P 248.13 requires.
  • No secondary use — No training, no sale, no reuse across clients, no enrichment without written instruction.
  • Security exhibit and 72-hour notice — The controls in sections 09 to 11, as binding terms.
  • Consent warranty — Your firm’s representation of how the leads were obtained.
  • Privacy requests — Access, correction and deletion within your deadlines, including state privacy laws for data outside the GLBA exemption.
  • Audit, return and destruction — Reasonable audit and questionnaire rights; return or certified destruction at termination.

16

Regulatory map

Each rule, and where it is addressed

RuleWhat it requires hereSection
Regulation S-P, 2024 amendmentsSafeguards, incident response, service-provider oversight, 72-hour vendor notice09 10 11
Regulation S-P 248.11 and 248.13Use limited to the contracted purpose07 15
Regulation S-IDIdentity theft red flags12
FINRA Rules 2210 and 3110Principal approval, content standards, supervision07 12
Exchange Act Rule 17a-4, FINRA Rule 4511Retention of business communications12
FINRA Rule 2040, Exchange Act section 15(a)No transaction-based pay to unregistered persons14
FINRA Notices 21-29 and 24-09Vendor oversight; AI under existing rules09 11 12
Advisers Act Rule 206(4)-1Advertisements and promoters12 14
Advisers Act Rules 204-2 and 206(4)-7Records; compliance program including vendors07 11 12
TCPA and the Do Not Call rulesConsent, revocation, Do Not Call, quiet hours13
State telemarketing lawsState consent and calling-hours rules13
CAN-SPAMUnsubscribe, address, accurate headers13
Massachusetts 201 CMR 17.00, New York SHIELD ActWritten security program, encryption10 11
State comprehensive privacy lawsAccess, deletion, no sale, for data outside the GLBA exemption15
NIST IR 8053, SP 800-188De-identification practice08 09

17

References

Every requirement, traced to its source

Each commitment in this document rests on a primary source: a statute, a regulation, a rule, a regulator’s own guidance, or a court decision. They are listed here so your compliance team can check our reading against the text. Links were current in October 2026.

Privacy and data securityRelied on forSections
Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809 (law.cornell.edu/uscode/text/15/chapter-94)The federal basis for protecting consumers’ nonpublic personal information07 08
Regulation S-P, 17 CFR Part 248, Subpart A (ecfr.gov/current/title-17/chapter-II/part-248)Service-provider exception (248.13); limits on reuse and redisclosure (248.11); who counts as a consumer07 08 15
SEC Release 34-100155, Regulation S-P amendments, May 2024 (sec.gov/files/rules/final/2024/34-100155.pdf)Incident response program, service-provider oversight, 72-hour vendor notice, 30-day customer notice01 07 11
SEC, Regulation S-P Small Entity Compliance Guide, 2024 (sec.gov/files/rules/final/2024/regulation-s-p-small-entity-compliance-guide.pdf)Plain-language reading of the amended requirements07 11
Regulation S-ID, 17 CFR Part 248, Subpart C (ecfr.gov/current/title-17/chapter-II/part-248)Identity theft red flags; why outreach never asks for personal details12
Massachusetts 201 CMR 17.00 (mass.gov/regulations/201-CMR-1700-standards-for-the-protection-of-personal-information-of-ma-residents)Written security program, encryption on laptops and in transit, service-provider contracts10 11
New York SHIELD Act, N.Y. Gen. Bus. Law 899-aa and 899-bbReasonable safeguards and breach notice for New York residents’ data11
California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq., incl. 1798.145(e)Data-level GLBA exemption; access, deletion and no-sale duties for data outside it15
State privacy law amendments narrowing GLBA exemptions: Oregon, Minnesota, Montana (Oct 2025), Connecticut (Jul 2026)Why privacy-request handling covers more than GLBA data15
Broker-dealersRelied on forSections
FINRA Rule 2210, Communications with the Public (finra.org/rules-guidance/rulebooks/finra-rules/2210)Correspondence versus retail communication; principal pre-approval; content standards12
FINRA Rule 3110, Supervision (finra.org/rules-guidance/rulebooks/finra-rules/3110)Review of correspondence; supervision of outsourced work07 12
FINRA Rule 4511 and Exchange Act Rule 17a-4, 17 CFR 240.17a-4 (finra.org/rules-guidance/rulebooks/finra-rules/4511)Retention of every business communication, text messages included12
FINRA Rule 2040, Payments to Unregistered Persons (finra.org/rules-guidance/rulebooks/finra-rules/2040)Why transaction-based fees to an unregistered vendor are restricted14
Securities Exchange Act of 1934, section 15(a), 15 U.S.C. 78o(a)Broker registration standard that Rule 2040 applies14
FINRA Regulatory Notice 15-07 (finra.org/rules-guidance/notices/15-07)FINRA’s guidance on Rule 2040 and the firm’s registration determination14
FINRA Regulatory Notice 21-29, Vendor Management and Outsourcing (finra.org/rules-guidance/notices/21-29)Outsourcing a function does not outsource the firm’s responsibility07 12
FINRA Regulatory Notice 24-09, Generative AI (finra.org/rules-guidance/notices/24-09)Existing rules apply in full when AI drafts a communication09 12
FINRA, 2026 Annual Regulatory Oversight Report, December 2025 (finra.org/sites/default/files/2025-12/2026-annual-regulatory-oversight-report.pdf)Vendor due diligence, vendors’ own use of AI, data return and destruction07 11
Investment advisersRelied on forSections
Advisers Act Rule 206(4)-1, Marketing, 17 CFR 275.206(4)-1; SEC Release IA-5653, December 2020 (sec.gov/files/rules/final/2020/ia-5653.pdf)Advertisements, promoters, compensated endorsements, written agreements12 14
SEC, Investment Adviser Marketing — Small Entity Compliance Guide (sec.gov/resources-small-businesses/small-business-compliance-guides/investment-adviser-marketing)The $1,000 de minimis exception; promoter disclosure and oversight14
Advisers Act Rule 204-2, Books and Records, 17 CFR 275.204-2Retention of written communications, texts included12
Advisers Act Rule 206(4)-7, Compliance Programs, 17 CFR 275.206(4)-7Policies and procedures that extend to service providers07 11
SEC Division of Examinations, Fiscal Year 2026 Examination Priorities (sec.gov/files/2026-exam-priorities.pdf)Exam focus on AI use, vendor oversight, Regulation S-P and S-ID09 11
SEC withdrawal of proposed rules, effective June 17, 2025, incl. predictive data analytics and adviser outsourcing proposals (sec.gov/rules-regulations/2025/06/s7-12-23)Why no AI-specific SEC rule applies, and existing rules govern instead12
NASAA, Investment Adviser Guide; Texas State Securities Board solicitor guidance (nasaa.org · ssb.texas.gov)State registration treatment of paid solicitors14
Telemarketing and emailRelied on forSections
Telephone Consumer Protection Act, 47 U.S.C. 227 (law.cornell.edu/uscode/text/47/227)Consent for marketing texts and calls; statutory damages; sender liability13
FCC rules, 47 CFR 64.1200Prior express written consent, Do Not Call, quiet hours, revocation of consent13
Telemarketing Sales Rule, 16 CFR Part 310Established business relationship: 18 months after a transaction, 3 months after an inquiry13
National Do Not Call Registry; FCC Reassigned Numbers Database (donotcall.gov · reassigned.us)The two checks run before any number is contacted13
Facebook, Inc. v. Duguid, 592 U.S. 395 (2021)Scope of the federal autodialer definition13
Insurance Marketing Coalition v. FCC (11th Cir., January 24, 2025)Vacatur of the FCC’s one-to-one consent rule13
McLaughlin Chiropractic Associates v. McKesson Corp. (U.S. Supreme Court, June 2025)Courts are not bound by FCC interpretations of the TCPA13 18
Florida Telephone Solicitation Act, Fla. Stat. 501.059; Texas SB 140 (2025), Tex. Bus. & Com. Code ch. 302State rules that treat texts as solicitation, applied by the lead’s state13
CAN-SPAM Act, 15 U.S.C. 7701 et seq.; FTC compliance guide (ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business)Unsubscribe within 10 business days, physical address, accurate headers13
De-identification and AIRelied on forSections
NIST IR 8053, De-Identification of Personal Information, 2015 (nvlpubs.nist.gov/nistpubs/ir/2015/NIST.IR.8053.pdf)Quasi-identifiers, re-identification risk, why pseudonymization is reversible08 09
NIST SP 800-188, De-Identifying Government Datasets, 2023 (csrc.nist.gov/pubs/sp/800/188/final)Generalization of figures into bands; de-identification as risk reduction08 09
NIST SP 800-122, Guide to Protecting the Confidentiality of PII, 2010 (csrc.nist.gov/pubs/sp/800/122/final)Classifying which fields are identifying and how sensitive each is08
Anthropic, Commercial Terms of Service (anthropic.com/legal/commercial-terms)No training on commercial API inputs and outputs by default09 15

18

Limits

What this document is not

  • 01Not legal advice — Your Chief Compliance Officer and counsel decide how these rules apply to your firm. This document tells them what we do so they can.
  • 02Not a SOC 2 report — We do not hold a SOC 2 attestation. We complete your due diligence questionnaire and provide the policies and evidence behind each control instead.
  • 03Not a registered firm — Tez I Solutions is not a broker-dealer or investment adviser, does not give investment advice, and does not solicit securities transactions.
  • 04Not permanent — Current as of October 2026. Rules in this area are moving — the FCC’s consent revocation rules among them. We review this document at least once a year and whenever a rule it relies on changes.
  • 05Not a promise of results — A score says which prospects to contact first, not who will book. Until your firm’s own outcomes are recorded, the odds behind it are estimates drawn from your team’s experience.

Part 2

AI services

How we handle your data inside your AI tools.

AI services puts a standing AI engineer across the AI tools your business already pays for — ChatGPT, Claude, Copilot, Gemini and the AI inside the software you use. We connect those tools to your CRM, inbox, calendar and files, build the workflows that do the repeat work, set up your processes and brand voice inside them, train your team, and look after the accounts. The tools stay yours, under your own contracts with each vendor. That changes how data protection works. In lead reactivation we keep names and contact details away from the AI provider by design. Here, a tool connected to your CRM will see the records it needs to do its job, names included. So the protections in this document are about something else: whose account it is, what each connection can reach, what the vendor's terms allow, who approves a workflow before it goes live, and how our access ends. Sections A1 to A6 are the same for every business we work with. Your industry's page adds sections A7 and A8: what your industry's rules mean for your AI tools, and where those rules come from.

A1

Commitments

Ten commitments, before the detail

  • 01 · Your accounts, on business terms — We work only in accounts your business owns, on business plans. Never in a personal or consumer account — ours, yours or an employee's.
  • 02 · A named user, never a shared password — You add us as a named user with our own sign-in and multi-factor authentication. We never ask for a shared password, and you should never send one to us by email.
  • 03 · The least access that does the job — Each connection reaches only the data its workflow needs. Admin rights are used for set-up tasks, logged, and reduced afterwards.
  • 04 · Nothing goes live without your approval — Every connection, workflow and set of instructions is approved by you, in writing, before it is switched on. So is every change to one that is already running.
  • 05 · Automated where it is routine, a person in the loop where it is not — Routine, rule-based work can run on its own once you have approved it: sorting and tagging, summaries for your team, filing, and fixed-wording notices such as an appointment reminder from a template you signed off. Anything that needs a decision or a judgement — a reply written for a particular customer, a price, a term, a commitment, or anything your industry's page marks for review — has a person on your side in the loop before it goes anywhere. Each workflow's data sheet (A3) states which kind it is. Where your industry's page requires a person to review every customer message, that rule applies instead.
  • 06 · Your data stays in your tools — We build and test inside your workspace. We do not copy your business data into Tez's own AI accounts. Where we need examples outside your tools, we use made-up records.
  • 07 · Your data serves your business only — No reuse across clients, no sale, no training of anything by us. Prompts, instructions and workflows built from your material are yours and are not reused for anyone else.
  • 08 · Vendor data settings confirmed in writing — During onboarding we read each tool's current data terms, set its controls with you, and give you a written record. We re-check it whenever a vendor changes its terms.
  • 09 · Incident notice within 72 hours — As soon as possible and no later than 72 hours, or sooner where your industry's page says so.
  • 10 · Access removed, everything handed over — At the end, our access is removed, every credential we created is revoked or rotated, and every workflow is documented and handed over. We confirm it in writing within 30 days.

Evidence on request: every control in this document has a record you can inspect, listed in section A5. If you send us a security questionnaire, we complete it during onboarding.

A2

Accounts and access

Whose accounts, and how we get in

The AI tools, the systems they connect to and the accounts that run them all belong to your business. We are given access to them; we never hold them. That is what makes the work portable: if we part ways, everything keeps running and nothing has to be moved out of our name.

Nothing in this section starts before you have decided to work with us. The first session is a conversation. We do not ask for logins, exports or files beforehand.

Who owns what

ItemWho owns itHow we handle it
AI subscriptions and workspacesYour business — in its name, on its payment methodWe administer them for you. If a new tool would genuinely pay for itself, we say so and why, and it goes on your account, not ours.
The owner or super-admin roleYour business keeps it, with at least one person on your side who is not usWe take the lowest role that does the work. Admin rights for a set-up task are logged and reduced when the task is done.
Our sign-inA named user for each Tez person, in your directory or invited as a guestMulti-factor authentication on. No shared logins. Never a password by email, text or chat.
Connections — API keys, app authorisations, service accountsCreated in your accounts, owned by youEach one is named, listed in the access record (A5), scoped to its workflow, and stored where you control it — never pasted into a document or a message.
Personal and consumer AI accountsTheir ownersNot used for business work. If the audit finds business work in personal accounts, we tell you and recommend moving it to business seats. We never connect your systems to a personal account.

How access is set up

  • 01 · You decide what we need — We list the systems and the role each one needs, and why. You agree or strike items out.
  • 02 · You add us — Usually by adding us as a user, on a call where we walk through it together. A password is never sent.
  • 03 · We confirm the safeguards — Multi-factor authentication on, role as agreed, sign-in recorded in the access record.
  • 04 · Reviewed every quarter — We go through the access record with you and remove anything no longer needed.
  • 05 · Removed at the end — Section A5 sets out how access ends.

Roles

ObligationYour businessTez I Solutions
Contracts with AI vendorsHolds them; the vendor processes your data under themReads the data terms and records them for you (A4)
Who on your team uses which toolDecidesSets up the seats and permissions you decide
Approval of workflows and changesApproves before anything goes liveProposes, documents and builds; never switches on without approval
Review of customer-facing outputYour people review before sendingBuilds the review step into the workflow
Industry rules — licensing, records, supervision, privacy noticesOwns themBuilds to them as set out on your industry's page (A7)
Security of the access we holdOverseesOperates the controls in A5
Notice to customers or regulators after an incidentDecidesTells you within 72 hours and supports the investigation
Privacy requests from your customersReceives and instructsHelps find and remove the data in the tools we set up, within your deadline

Where a state privacy law reaches your business, we act as your service provider or processor for the access we hold, and the agreement says so.

A3

What the tools can see

Connections, scopes, and what stays out

An AI tool connected to one of your systems can see whatever that connection lets it see. An assistant that searches your files can surface anything the person using it is allowed to open — Microsoft says of its own Copilot that it "only surfaces organizational data to which individual users have at least view permissions." So the work starts with permissions, not prompts.

Before anything is connected

  • Who can see what — Before an assistant is pointed at a shared drive, inbox or CRM, we review who can open what. Folders that are open to everyone but should not be are fixed first, with your approval.
  • One data sheet per workflow — Every workflow gets a written sheet: what it reads, what it writes, who sees the result, and where a person reviews it. You approve the sheet before we build.
  • Add-ons are vendors too — A plug-in, connector, custom GPT or agent from a third party is another company handling your data. None is installed without your approval and a record of its data terms.

What a data sheet looks like

Illustration — not real client data.

WorkflowReadsWritesWho sees the resultHuman in the loop
Morning summary of new inquiriesCRM records created in the last 24 hours: name, source, service asked about, notesOne summary in the office manager's inboxOffice managerRead before anyone acts on it
First-draft reply to a quote requestThe single inquiry being answered; your approved reply templates and brand voiceA draft in the shared inbox — never sentThe person replyingEdited and sent by a person
Meeting notes to CRMThe transcript of a meeting the attendees agreed to recordA note on the matching CRM recordThe account ownerChecked before it is saved

What stays out by default

Unless your written decision says otherwise, after we have shown you what the vendor's terms and your industry's rules say, these are kept out of every prompt, instruction file and connection:

  • Social Security numbers, tax IDs, driver's licence and other government ID numbers
  • Full bank account and card numbers
  • Passwords, access codes, gate, door and alarm codes
  • Health information
  • Anything your industry's page (A7) marks as restricted

Where a connection would expose one of these — a folder of scanned IDs, a CRM field holding card numbers — the connection is narrowed to leave it out, or not built.

Before a workflow goes live

CheckWhat has to be true
Data sheetApproved by you, in writing
AccessThe connection reaches only what the sheet lists
TestRun on made-up records, or on a small set of real ones you choose, with the results shown to you
Human in the loopMarked on the data sheet. In place wherever a decision or judgement is involved: a reply written for a particular customer, a price or a term, or anything your industry's page marks for review. Routine, rule-based steps you have approved may run without one
OwnerA named person on your side who can pause it
DocumentationWritten up and stored where you keep it

AI tools make mistakes. Every workflow is built on the assumption that a draft can be wrong, which is why the review step is part of the design rather than a suggestion.

A4

Model providers and training

What the vendors do with your data, and how we check

When your team or a workflow uses ChatGPT, Claude, Copilot or Gemini, the vendor processes that data under its contract with your business. Tez is not a reseller or partner of any AI vendor, and not a party to those contracts. Whether a vendor trains its models on your data, how long it keeps prompts, whether its staff can review them, and where it processes them are set by the vendor's terms and by the plan you are on. Those terms change. So we do not promise what a vendor will do. We promise what we will do.

What we do

  • 01 · List every tool — Each AI tool and AI feature you pay for, the plan it is on, and who holds a seat.
  • 02 · Read the current terms — For each one we record what the vendor says about training on your data, retention, human review, where data is processed, and which admin controls exist. Each entry carries the date and the address of the page we read.
  • 03 · Set the controls with you — Where a tool offers a choice — training opt-outs, retention periods, chat history, which add-ons are allowed — we recommend the most protective setting that still does what you need, and you decide.
  • 04 · Give you the record — The settings record is yours, in writing. Your compliance contact can file it with your vendor reviews.
  • 05 · Re-check when terms change — When a vendor changes its data terms, we re-read them, update the record and tell you if anything moved. We also re-check the whole record at least every six months.

What the main vendors said when we checked

Read on each vendor's own page on 6 October 2026. This is the vendor's statement to its customers, not a commitment by Tez. If it changes, the vendor's current terms govern, and we update your record.

VendorWhat its page saidWhere
Anthropic — Claude, under its Commercial Terms"Anthropic may not train models on Customer Content from Services." The Commercial Terms cover Anthropic's API and the business offerings that reference them, not its consumer plans. Effective June 17, 2025.anthropic.com/legal/commercial-terms
OpenAI — APIData sent to the API is not used to train or improve OpenAI's models unless you opt in, as of March 1, 2023. Abuse-monitoring logs are kept for up to 30 days by default.developers.openai.com/api/docs/guides/your-data
OpenAI — ChatGPT business plansRead during onboarding against OpenAI's published terms for your plan, and recorded the same way.openai.com/enterprise-privacy
Microsoft — Copilot"Prompts, responses, and data accessed through Microsoft Graph aren't used to train foundation LLMs." Copilot only surfaces data a user already has permission to view.learn.microsoft.com/en-us/microsoft-365/copilot/microsoft-365-copilot-privacy
Google — Gemini in Google WorkspaceYour content "is not human reviewed or otherwise used for Generative AI model training outside your domain without permission."knowledge.workspace.google.com/admin/gemini/generative-ai-in-google-workspace-privacy-hub
AI inside your other softwareEach vendor's own terms — your CRM, phone system or accounting software. Recorded the same way during onboarding.Each vendor's data or AI terms page

Consumer plans and personal accounts

Consumer plans run on different terms from business plans — Anthropic's Commercial Terms, for one, state that they do not cover its consumer offerings. We do not do business work in consumer or personal accounts, and we do not rely on a consumer plan's settings to protect business data.

Our own tools

We use AI tools of our own to write code and documentation. Your business data does not go into them. Anything we build for you is built and tested in your workspace, or against made-up records.

A5

Records, security and incidents

What we keep, how it is protected, and what happens if something fails

Records you can inspect

Records describe what we built and changed. They live in a location your business owns, and they do not contain your customers' data.

RecordWhat it holds
Access recordEvery Tez sign-in and every connection we created: system, role or scope, date added, date reviewed, date removed
Settings recordEach tool's plan, data terms as read on a given date, and the controls set (A4)
Workflow registerEvery live workflow, with its approved data sheet (A3), its owner on your side and its documentation
Change logEvery change to a live workflow or connection: what changed, why, when, who approved it
Training recordWho was trained, on which tools and processes, and when

Changes to something already running

Every change to a live workflow is described, approved by you, tested, logged and reversible — the previous version is kept. If a vendor update breaks a workflow, or a workflow starts doing something it should not, we may pause it at once to stop harm, and tell you the same day. We do not change what a workflow does without your approval.

Security controls

ControlEvidence you can ask for
Written information security program, modelled on Massachusetts 201 CMR 17.00The program document
Multi-factor authentication on every account we use to reach your systemsAccess record
Access limited to named individuals, reviewed with you quarterlyAccess record and review log
Tez devices: full-disk encryption, screen lock, current patches, endpoint protectionConfiguration record
Your data is not stored on Tez devices or in our cloud storage; where a task needs a file locally, it is deleted when the task endsWritten procedure
Background check for anyone with access, on your requestWritten confirmation
Cyber liability insurance, where your contract requires itCertificate of insurance
Written incident response plan, reviewed each yearThe plan and its last review

If something goes wrong

An incident includes a workflow sending or showing data to the wrong person, a connection reaching more than its sheet allows, a suspected compromise of a Tez sign-in, and a vendor incident we learn of that affects your workspace.

  • 01 · Contain — Pause the workflow, revoke the affected credential or connection, and stop the exposure.
  • 02 · Notify you within 72 hours at the latest — Which systems and data, what window, what we have done. Sooner where your industry's page sets a shorter time. Updates follow as we investigate.
  • 03 · Preserve evidence — Logs, the change log and the vendor's audit records are kept intact for your investigation.
  • 04 · Support your notice, never pre-empt it — Whether customers or regulators are told is your decision. We never contact your customers about it. A vendor's own incident notice comes to you under your contract with that vendor.

When the engagement ends

StepWhat happens
Access removedEvery Tez user and role removed from every system, checked against the access record
Credentials endedEvery key, app authorisation and service account we created is revoked, or rotated and handed to you
Nothing in our nameAnything that ended up in a Tez name is transferred to you first — by design there should be nothing
Handover packThe workflow register, data sheets, settings record, change log and plain-English run notes, so your team or the next provider can keep it running
Written confirmationWithin 30 days of the end of the engagement

Everything we build is yours — documented and portable. If we part ways, it keeps working and your team knows how it runs.

A6

Limits

What this document is not

  • 01 · Not legal advice — Your counsel or compliance officer decides how your industry's rules apply to your business. This document tells them what we do so they can.
  • 02 · Not a SOC 2 report — We do not hold a SOC 2 attestation. If you send a security questionnaire, we complete it and provide the policies and evidence behind each control instead.
  • 03 · Not the vendor — We do not run the AI vendors' systems or set their terms. Their security, retention, outages and incidents are governed by your contract with them. We are not a reseller, partner or certified provider of any AI vendor.
  • 04 · Your obligations stay yours — Using AI tools does not move your duties to us: licensing, supervision, record keeping, privacy notices and your staff's use of AI remain your business's responsibility. We build to them, as your industry's page sets out.
  • 05 · Not a promise about AI output — AI tools can be wrong, and confidently so. That is why anything that needs a judgement has a person in the loop, and why no workflow makes a decision your business would otherwise make.
  • 06 · Not permanent — Current as of October 2026. Vendor terms and the rules on AI change often. We review this document at least once a year, and whenever a vendor term or rule it relies on changes.

A7

Financial advisory

What your industry's rules mean for your AI tools

No rule written for AI binds a broker-dealer or investment adviser today. The SEC withdrew its AI proposal in June 2025 [8], and FINRA has said its existing rules apply whether a firm builds an AI tool or uses a vendor's [5]. That makes the familiar rules the standard: Regulation S-P for customer information, supervision and approval for communications, and books and records for everything sent. Each one reaches AI tools directly. These are the rules, and what we do about each.

RuleWhat it means for AI toolsHow we handle it
Regulation S-P, as amended in 2024 [1][2]Every AI vendor and every outside engineer that can reach customer information is a service provider your firm must oversee. The amended rule requires your firm to make sure service providers notify it of a breach within 72 hours. Prospects who never opened an account are still consumers under the rule.Incident notice to you within 72 hours, in our agreement. The settings record and access record (A4, A5) are written for your vendor oversight file. We inventory every AI tool that can reach customer information, including ones staff added themselves.
Regulation S-P, 248.11 and 248.13 [1]Customer information shared with a service provider may be used only for the contracted purpose.Our use is limited to your engagement, in writing. We record whether each AI vendor's terms allow it to use your data for anything else, and set the controls with you.
Regulation S-ID [1]Identity theft red flags. An AI tool that drafts outreach or answers clients must never ask someone to confirm account or personal details.Drafts never request account numbers, dates of birth or verification details. Account-specific questions are routed to a person.
FINRA Rules 2210 and 3110; FINRA Notice 24-09 [3][4][5]An AI-drafted message is still your firm's communication. Templates used with more than 25 retail investors in 30 days need principal approval before use; correspondence is reviewed under your supervisory procedures.Every customer-facing draft is reviewed by a person at your firm. Templates go to your principal before use. No workflow sends to clients without review.
Advisers Act Rule 206(4)-1, the Marketing Rule [6]Outreach offering advisory services may be an advertisement. AI tools add performance figures, projections and testimonial-style lines freely.Brand-voice instructions bar performance figures, projections, testimonials and guarantees. Your CCO classifies and approves each template.
Exchange Act Rule 17a-4, FINRA Rule 4511, Advisers Act Rule 204-2 [7]Business communications must be preserved in your archive. A message an AI workflow sends from a channel your archive does not capture is an off-channel record.Workflows send, if at all, only through channels your archive already captures. AI notetakers and chat assistants are set up so that anything your CCO treats as a record lands where your archive can keep it.
FINRA Notice 21-29; Advisers Act Rule 206(4)-7 [9][10]Outsourcing a function does not outsource responsibility. Your compliance program has to cover vendors — including how vendors themselves use AI.We complete your due diligence questionnaire, say which AI tools we ourselves use (A4), and confirm that your data does not go into them.
State privacy laws narrowing the GLBA exemption [11]Data outside the federal exemption — and in some states, more — can carry state access and deletion rights.We help locate and remove that data in the tools we set up, within your deadline.

In practice

  • A workflow may draft a meeting follow-up for an advisor to edit and send through your archived email. It does not send on its own, and it never includes performance figures or a recommendation.
  • An assistant may answer staff questions from your written policies and procedures. It is not given access to custodian data or account statements unless your CCO approves that scope in writing.
  • An AI notetaker is switched on only for meetings your firm has decided to record, and its notes are kept where your archive can preserve them.
  • During onboarding we check for AI tools staff are using on client data without approval, and list them for your CCO.

A8

Sources

Where these rules come from

1. Regulation S-P and Regulation S-ID, 17 CFR Part 248 — https://www.ecfr.gov/current/title-17/chapter-II/part-248 2. SEC Release 34-100155, Regulation S-P amendments, May 2024 — https://www.sec.gov/files/rules/final/2024/34-100155.pdf · SEC, Regulation S-P Small Entity Compliance Guide — https://www.sec.gov/files/rules/final/2024/regulation-s-p-small-entity-compliance-guide.pdf 3. FINRA Rule 2210, Communications with the Public — https://www.finra.org/rules-guidance/rulebooks/finra-rules/2210 4. FINRA Rule 3110, Supervision — https://www.finra.org/rules-guidance/rulebooks/finra-rules/3110 5. FINRA Regulatory Notice 24-09, Generative AI — https://www.finra.org/rules-guidance/notices/24-09 6. Advisers Act Rule 206(4)-1; SEC Release IA-5653 — https://www.sec.gov/files/rules/final/2020/ia-5653.pdf 7. FINRA Rule 4511 and Exchange Act Rule 17a-4 — https://www.finra.org/rules-guidance/rulebooks/finra-rules/4511 8. SEC withdrawal of proposed rules, effective June 17, 2025 — https://www.sec.gov/rules-regulations/2025/06/s7-12-23 9. FINRA Regulatory Notice 21-29, Vendor Management and Outsourcing — https://www.finra.org/rules-guidance/notices/21-29

  • 01FINRA, 2026 Annual Regulatory Oversight Report — https://www.finra.org/sites/default/files/2025-12/2026-annual-regulatory-oversight-report.pdf · SEC Division of Examinations, Fiscal Year 2026 Examination Priorities — https://www.sec.gov/files/2026-exam-priorities.pdf
  • 02Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809 — https://www.law.cornell.edu/uscode/text/15/chapter-94

Questions your counsel or compliance team wants answered first?

We go through this document on the free first session, and complete your security or due-diligence questionnaire during onboarding.

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