Key facts
- When a system does part of advisory work, the firm's memory depends on three things captured at the time: what the system saw, what it produced, and what the person decided.
- Rule 204-2(a)(7) requires an SEC-registered adviser to keep copies of written communications sent relating to advice; the sent version is the record, whoever drafted it.
- Rule 206(4)-7 requires written compliance policies reasonably designed to prevent violations; a supervision policy that cannot show a person approved AI-drafted client work is hard to describe as reasonably designed.
- A firm's own record, in its own systems, is the only version of "asking the person who was there" that works for machine-assisted work.
Pick one recent piece of AI-assisted client work
A meeting summary, a client email, a plan section, a review note. Something a system drafted and a person approved within the last month. Hold that one item in mind and answer from the record alone, not from memory. If you would have to ask the advisor, the answer is "no."
Result
What the three parts are testing
Part one tests whether the output can be traced to its inputs; without that, emphasis and omissions can be observed but never explained. Part two tests whether the machine's contribution and the person's are still distinguishable, which is where professional judgment lives. Part three tests whether the human decision exists as a recorded event rather than as silence. A firm that scores well on all three can hand the work forward. A firm that scores well on none has a record it cannot retrace, however polished the finished artifact looks.
Questions
Why one piece of work rather than a policy review?
Because a policy states what the firm intends and a record shows what happened. Ten minutes with one real file teaches more about the firm's actual memory than an afternoon with the manual.
What counts as a good score?
A record that lets a stranger answer all three core questions, what the system saw, what it produced, and what the person decided, without asking anyone. The scoring bands on the page explain what each range means and what to change first.
Does this page keep my answers?
No. The answers are scored in your browser and shown on the page. Nothing is transmitted, saved, or measured. Print the result if you want to keep it.
Is this a Rule 204-2 assessment?
No. Rule 204-2 lists categories of required records and the firm decides which items fall into them. The test measures whether the record supports reconstruction, which matters for supervision and succession whether or not a given item is a required record.
Primary sources
General information from ValaisOS LLC, not legal, compliance, tax, or investment advice. Confirm requirements for your firm with counsel. See Terms of Use.