Regulation first
Intelligence shaped for accountable advisory work.
ValaisOS is being designed as a governed intelligence and review layer over a firm’s established information environment—not as a replacement for its repository, records authority, or professional judgment.
The operating thesis
The firm remains the authority.
AI can widen inquiry, connect evidence, and prepare proposed work. The firm still determines what may be accessed, which policies apply, who may approve an outcome, and what may enter its established records workflow.
Five operating principles
Regulatory responsibility expressed through product design.
- 01
Evidence before assertion.
Material work should remain connected to its source, version, assumptions, and relevant context.
- 02
Review before action.
AI may assist analysis and preparation. Accountable professionals retain approval authority for consequential work.
- 03
Records with continuity.
Decisions, revisions, approvals, and supporting material should remain understandable and reviewable.
- 04
Policy before autonomy.
Firm-approved permissions, processing choices, and workflows define what an automated system may do.
- 05
Responsibility remains human.
Technology does not replace an adviser’s fiduciary, supervisory, legal, or compliance responsibilities.
The AI operating boundary
Extend professional capacity without obscuring professional responsibility.
ValaisOS is being designed so model-assisted work remains identifiable, reviewable, attributable, and subject to authorized approval.
- AI involvement remains visible.
- Sources and assumptions remain inspectable.
- Material outputs pass through review.
- Permissions constrain available actions.
- Corrections preserve decision history.
- Final responsibility remains with the firm and its authorized professionals.
Regulatory alignment
Design relevance—not a compliance conclusion.
These relationships describe where the ValaisOS design direction may support a firm’s own controls. Applicability and implementation remain firm-specific.
| Regulatory concern | ValaisOS design direction |
|---|---|
| Books and records | Preserve source context, versions, review, approval, and a clear promotion event into the firm’s designated workflow. |
| Compliance programs | Represent firm policy as a visible operating input rather than produce a generic compliance determination. |
| Marketing oversight | Support substantiation, balanced review, attributable source material, and retained approval evidence. |
| Privacy and safeguarding | Favor minimized access, firm-governed processing choices, controlled data movement, and incident readiness. |
| Fiduciary responsibility | Keep professional judgment, material review, and accountable approval explicit. |
Examination readiness in mind
Designed to make consequential work easier to reconstruct.
The product direction favors retrievable evidence, visible decision history, documented approvals, clear responsibility boundaries, and explicit handoff into firm-designated systems. Examination readiness depends on the firm’s complete implementation and operating procedures.
Public regulatory design register
A versioned view of the design commitments.
This register records public product direction. It is not a control certification, legal interpretation, or representation that a feature is generally available.
| Topic | Design commitment | Authority considered | Status |
|---|---|---|---|
| Records authority | The firm’s designated repository and records workflow remain authoritative. | Advisers Act books-and-records requirements and firm policy | Principle |
| Supervisory review | AI-assisted material remains proposed until the appropriate review or approval occurs. | Firm supervision and compliance policies | Product direction |
| Marketing substantiation | Material assertions should remain connected to evidence and review. | Advisers Act marketing and recordkeeping requirements | Product direction |
| Privacy and safeguarding | Access and processing should be minimized, controlled, and visible to the firm. | Regulation S-P and firm information-security policy | Principle |
| AI governance | The firm defines permitted providers, processing boundaries, permissions, and approval paths. | Firm policy and deployment-specific review | Product direction |