Rules and desks
The rule set is data. A change here is in force on the next evaluation, everywhere, with no release.
12 rules are in force across 8 desks for this advisor. I read 16 findings from the last 90 days and propose 3 changes, stricter only, for a principal to accept or refuse. 1 attempted loosening was refused and stays on the record.
- Undisclosed outside business activity signal: turn it on. Undisclosed outside business activity signal is not in force, and the language it looks for was seen 2 times in 90 days.
- Retail communication crossing the pre-approval threshold: threshold from 25 to 20. 3 drafts in 90 days cleared within 15 percent of the retail investors in a rolling 30 days of 25. Reviewing at 20 keeps this segment clear of the line rather than on it.
- Possible diminished capacity or financial exploitation: severity from flag to block. Every one of 2 findings in 90 days was confirmed by a principal. A rule that is never cleared is a block wearing a flag.
Every layer can tighten and none can loosen. A refused change is itself a supervision signal, so it is kept.
Proposed by the agent, waiting on a principal
The proposer reads what the other agents keep finding, over the last 90 days (16 findings) and the current sweep, and drafts a change in the stricter direction only. It applies nothing: accepting one appends an edit to the change log in your name, through the same resolver as any other change.
Undisclosed outside business activity signal
enabled false to true, at the firm layer
undisclosed outside business activity signal is not in force, and the language it looks for was seen 2 times in 90 days.
Learner: off-but-firing. A proposal the resolver would refuse never reaches this screen.
Retail communication crossing the pre-approval threshold
threshold 25 to 20, at the segment private-wealth layer
3 drafts in 90 days cleared within 15 percent of the retail investors in a rolling 30 days of 25. Reviewing at 20 keeps this segment clear of the line rather than on it.
Learner: near-threshold. A proposal the resolver would refuse never reaches this screen.
Possible diminished capacity or financial exploitation
severity flag to block, at the firm layer
Every one of 2 findings in 90 days was confirmed by a principal. A rule that is never cleared is a block wearing a flag.
Learner: always-confirmed. A proposal the resolver would refuse never reaches this screen.
Seen, not proposed: Holdings drifted outside the stated profile
Fired 3 times in 90 days on one account and was cleared every time: "Cleared again. This is the household's own limit, not a breach."
Why the agent will not draft this: This pattern argues for loosening the rule or its parameter, and an agent may only propose in the stricter direction. A principal at the firm layer decides whether the parameter fits this household; Relay will not draft that change.
1 change was refused
- advisor tried to set maxConcentration to 35 on finra-2111-suitability. Would loosen Single-name concentration ceiling. A lower layer may only move it in the stricter direction.
Who is editing
Firm, then segment, then advisor, then client. A lower layer can only tighten.
What tighten-only means, exactly
Review desks, as they stand for Margaret Ellison
One agent per team a legal, risk and compliance function runs. Each detects, classifies and assembles evidence on its own, and dispositions nothing.
AgentCommunications review
On every draft and message. 4 rules, 4 evaluable with what is connected.
AgentMarketing and advertising review
Daily. 1 rule, 1 evaluable with what is connected.
AgentComplaints
On every draft and message. 1 rule, 1 evaluable with what is connected.
AgentBooks and records
Daily. 2 rules, 2 evaluable with what is connected.
AgentReg BI review
On every proposal. 1 rule, 1 evaluable with what is connected.
AgentSales practice supervision
Daily. 2 rules, 2 evaluable with what is connected.
AgentSenior and vulnerable investors
Daily. 1 rule, 1 evaluable with what is connected.
AgentRegistered representative conduct
Weekly. 1 rule, 1 evaluable with what is connected.
Why the desks are data, and what an advisor layer may change
Live sample: record completeness
The configuration above, run against this advisor's actual coverage. Change a rule and this changes with it.
Business conducted on an uncaptured channel
Record completeness · SEC Rule 17a-4; Exchange Act Section 17(a)
calendar, voice, sms, chat, social in use with nothing capturing them. Record completeness is 0.36.
Suggested: Connect a capture source for each channel, or prohibit the channel and attest to it.
No retained copy behind a captured channel
Record completeness · SEC Rule 17a-4(b)(4), 17a-4(f)
meeting, crm captured but held by no system of record. Evidence exists and retention does not.
Suggested: Point the channel at the archive, which is the 17a-4 copy, by WORM or the audit-trail alternative.
The rule set
Retail communication crossing the pre-approval threshold
FINRA · FINRA Rule 2210(a), (b)(1)
Fires when retail recipients in 30 days is more than 25 and not: a principal approved it
Communications surveillance
Correspondence not reviewed under written supervisory procedures
FINRA · FINRA Rule 3110(b), 3110.06 to .09
Fires when retail recipients in 30 days is at most 25 and not: it has been reviewed and it contains a recommendation
Communications surveillance
Business conducted on an uncaptured channel
SEC · SEC Rule 17a-4; Exchange Act Section 17(a)
Fires when channels in use and not captured is present or record completeness is under 1
Record completeness
No retained copy behind a captured channel
SEC · SEC Rule 17a-4(b)(4), 17a-4(f)
Fires when channels read but not retained is present
Record completeness
Recommendation without a documented reasonable basis
SEC · SEC Rule 15l-1(a)(2)(ii), care obligation
Fires when it is a recommendation and alternatives considered is under 2 or not: costs are compared or not: the basis is recorded
Recommendation evidence
Performance or testimonial content in advisory-capacity material
SEC · SEC Rule 206(4)-1, Advisers Act marketing rule
Fires when it projects performance or it contains a testimonial
Marketing review
Possible diminished capacity or financial exploitation
FINRA · FINRA Rules 2165 and 4512(a)(1)(F)
Fires when the client's age is at least 65 and a disbursement is unusual or a new third party is in contact or not: a trusted contact is on file
Vulnerable client protection
Unlogged client complaint
FINRA · FINRA Rule 4513
Fires when the text reads as a complaint and not: a complaint is logged
Complaints
Holdings drifted outside the stated profile
FINRA · FINRA Rule 2111
Fires when the share of wealth in one name (%) is more than 25
Sales practice
Client identifying data on an unapproved channel
SEC · Regulation S-P, as amended 2024
Fires when it contains sensitive personal data and not: the channel is approved
Communications surveillance
Generated client-facing text released without grounding
FINRA · FINRA Regulatory Notice 24-09; 2026 Annual Regulatory Oversight Report, GenAI
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
Communications surveillance
Undisclosed outside business activity signal
FINRA · FINRA Rules 3270 and 3280
Fires when it mentions outside business and not: an outside activity is disclosed
Conduct
Concentration rising toward the household's ceiling
FINRA · FINRA Rule 2111(a), quantitative suitability, read over time rather than at a point
Fires when the rise in one name over 90 days (points) is more than 5 and headroom under the family's one-name limit (points) is under 10
Sales practice
Every change lands in the change log, with who made it, when, at which layer and why.