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12 findings

Margaret Ellison, advisor (synthetic persona)Senior advisor, founder and executive practice, New YorkAbout $820M across 183 households; four relationships above $50M; 7 of those households are in this prototypeWho's who

Communications review

Communications surveillance. The electronic communications review team: correspondence sampling, the retail communication line, privacy on approved channels, generated text under supervision.

Agent read or preparedYou decide or sendClient said or holds

Communications surveillance · ran day 0, 06:25

I read 5 captured messages on email for Margaret Ellison against 4 rules. I raised 1 finding, and prepared 2 actions; 2 still wait on you.

Open the findings

How I got there
  1. 1. AgentRead 5 captured messages on emailCadence: on every draft and captured message.
  2. 2. AgentApplied 4 rulesRetail communication crossing the pre-approval threshold; Correspondence not reviewed under written supervisory procedures; Client identifying data on an unapproved channel; Generated client-facing text released without grounding
  3. 3. AgentRaised what fired and what I was not sure ofA rule under its confidence floor reaches a person even when it clears.
  4. 4. YouLeft every disposition to a personI never clear my own findings.

Read every outbound draft and every captured message in both directions, decide the supervisory regime, and hold anything that cannot go out as written.

Reads
Every captured email and message, and every note before it goes to a client
Checks
Retail communication crossing the pre-approval threshold; Correspondence not reviewed under written supervisory procedures; Client identifying data on an unapproved channel; Generated client-facing text released without grounding
Prepares
a hold until a principal decides; a drafted note, which a person sends; a task with an owner
Runs
On every draft and captured message
Never
Never sends, never clears its own finding, and no advisor can switch it off or loosen it without a principal.
How
4 rules, each a stated condition over facts computed from the book; under a rule's confidence floor, or without the source it needs, it asks a person rather than clears.
Built on
FINRA Rule 2210, Communications with the Public; FINRA Rule 3110, Supervision; Regulation S-P, 17 CFR Part 248, Subpart A; FINRA reminder on the Regulation S-P compliance dates; FINRA Regulatory Notice 24-09; FINRA 2026 Annual Regulatory Oversight Report

Read a written policy into it

Needs youRunningFINRA 3110FINRA 2210FINRA 24-09Reg S-POn every draft and captured message. Last run day 0, 06:25.

Rules this desk watches (4)

Each rule is data: a stated condition over facts computed from the book, the settings a layer may tighten, what the desk prepares when it fires, and the text it is built on with where that text stands in law today.

Retail communication crossing the pre-approval threshold

Block

FINRA · FINRA Rule 2210(a), (b)(1) · firm-mandatory

Fires when
retail recipients in 30 days is more than 25 and not: a principal approved it
Settings
Retail investors in a rolling 30 days: 25 (bounds 1 to 25, stricter is lower)Rule 2210(a) sets 25. A firm may supervise below it; it may not supervise above it.
Prepares
a hold until a principal decides; a drafted note, which a person sends
Needs
Microsoft 365 mail and calendar, Communications archive
In law
In force; the current rule took effect on February 4, 2013.
Source
FINRA Rule 2210, Communications with the Public
Today
Nothing fired.

Change this rule

Correspondence not reviewed under written supervisory procedures

Flag for review

FINRA · FINRA Rule 3110(b), 3110.06 to .09 · firm-mandatory

Fires when
retail recipients in 30 days is at most 25 and not: it has been reviewed and it contains a recommendation
Settings
Correspondence ceiling: 25 (bounds 1 to 25, stricter is lower); Review sample rate for non-recommendation correspondence: 0.1 (bounds 0 to 1, stricter is higher)Correspondence is reviewed, not pre-approved. Recommendations are reviewed every time.
Prepares
a task with an owner; a drafted note, which a person sends
Needs
Microsoft 365 mail and calendar
In law
In force since December 1, 2014, when the consolidated supervision rule took effect.
Source
FINRA Rule 3110, Supervision
Today
Raised 1 for Margaret Ellison.

Change this rule

Client identifying data on an unapproved channel

Block

SEC · Regulation S-P, as amended 2024 · firm-mandatory

Fires when
it contains sensitive personal data and not: the channel is approved
Prepares
a hold until a principal decides; a task with an owner
Needs
Nothing beyond the book
In law
In force as amended in May 2024; compliance required from December 3, 2025 for larger entities and June 3, 2026 for smaller ones.
Source
Regulation S-P, 17 CFR Part 248, Subpart A; FINRA reminder on the Regulation S-P compliance dates
Today
Nothing fired.

Change this rule

Generated client-facing text released without grounding

Block

FINRA · FINRA Regulatory Notice 24-09; 2026 Annual Regulatory Oversight Report, GenAI · firm-mandatory

Fires when
it was drafted by a model and figures without a source is more than 0 or the number of cited sources is under 1
Settings
Minimum citations in generated client text: 1 (bounds 0 to 10, stricter is higher)Existing rules apply to AI tools. Grounding is the firm's evidence that they did.
Prepares
a hold until a principal decides; a task with an owner
Needs
Nothing beyond the book
In law
Guidance, not a rule: Regulatory Notice 24-09 (June 2024) and the 2026 Annual Regulatory Oversight Report (December 2025) say existing rules, including Rule 3110, apply to generated text.
Source
FINRA Regulatory Notice 24-09; FINRA 2026 Annual Regulatory Oversight Report
Today
Nothing fired.

Change this rule

Findings it raised (1)

AgentCorrespondence not reviewed under written supervisory proceduresRenner: email sent 2 days ago · Correspondence carrying a recommendation has not been through supervisory review.Flag for review

Tune this desk for Margaret Ellison

Editing asA lower layer can only tighten; a refused change stays in the log.

AgentCommunications review

Communications surveillance · The electronic communications review team: correspondence sampling, the retail communication line, privacy on approved channels, generated text under supervision.

Running

FINRA 3110FINRA 2210FINRA 24-09Reg S-P

On every draft and message. 4 rules, 4 evaluable with what is connected.

Why the desks are data, and what an advisor layer may change
Each desk is one entry in the agent catalog: the human team it mirrors, the authorities it applies, the rules it watches and its cadence. Adding a desk is adding an entry. An advisor's layer can switch a desk on, run it more often or give it another rule of its scope, and every change is an entry in the same change log the rules use, replayable to any past moment. It cannot switch a desk off, slow it down or take a rule away: the same tighten-only invariant the rule set has, enforced in the resolver and shown on the desk when an attempt is refused.

Teach this desk a policy

Paste or drop a written supervisory procedure. The reader turns each sentence that carries an obligation into a candidate rule in the same shape the engine runs, cited to the sentence. You add the ones that say what the firm meant; each is in force on the next sweep and lands in the change log in your name.

What the reader does

  • Keeps only sentences with an obligation: must, may not, is required.
  • Matches the facts the engines compute, by the words a policy uses for them.
  • Reads the number and the comparator beside each fact.
  • Takes severity from the verb: a prohibition blocks, a review flags.
  • Cites the rule the sentence cites, or the paragraph.

This is the deterministic reader. In production a model reads the sentence more freely; it still only proposes, and what it proposes is still this data.