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Relay
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

Rules and desks

The rule set is data. A change here is in force on the next evaluation, everywhere, with no release.

Rule proposer · ran day 0, 06:35

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.

Decide the first proposal

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

Proposed

undisclosed outside business activity signal is not in force, and the language it looks for was seen 2 times in 90 days.

  • h-008: Captured email, Thornbury, 2026-08-05, clear, cleared
  • h-009: Captured email, Thornbury, 2026-08-27, clear, cleared

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

Proposed

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.

  • h-003: Client draft, 11 households, 2026-09-03, clear, cleared
  • h-004: Client draft, 12 households, 2026-09-09, clear, cleared
  • h-005: Client draft, 12 households, 2026-09-19, clear, cleared

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

Proposed

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.

  • h-006: Okafor-Lind, 2026-08-21, flag, returned
  • h-007: Okafor-Lind, 2026-09-11, flag, blocked

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.

  • h-010: Thornbury, 2026-08-12, flag, cleared
  • h-011: Thornbury, 2026-09-02, flag, cleared
  • h-012: Thornbury, 2026-09-23, flag, cleared

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
A lower layer may enable a rule the firm left off, raise a severity, and move a threshold in the stricter direction. It may not disable a mandatory rule, lower a severity, or loosen a threshold. A refused change is recorded rather than dropped, because a layer that tried to loosen a rule is itself a supervision signal.

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

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.

AgentMarketing and advertising review

Marketing review · The marketing review desk: performance, projections and testimonials in advisory-capacity material, before it reaches a client.

Running

SEC 206(4)-1FINRA 2210

Daily. 1 rule, 1 evaluable with what is connected.

AgentComplaints

Complaints · The complaints desk: identify a grievance in what the client wrote, log it, and start the clock the reporting rule runs on.

Running

FINRA 4513FINRA 4530

On every draft and message. 1 rule, 1 evaluable with what is connected.

  • Refused at the Margaret Ellison layer: enabled to false. A lower layer cannot switch an agent off without a principal's approval. The desk runs for every advisor the firm runs it for.

AgentBooks and records

Record completeness · The books and records function: is every channel the advisor uses captured, retained and producible on request.

Running

SEC 17a-4FINRA 4511FINRA 3110

Daily. 2 rules, 2 evaluable with what is connected.

AgentReg BI review

Recommendation evidence · The care-obligation reviewer: basis, reasonably available alternatives, costs, and why this client, before a recommendation is released.

Running

Reg BI

On every proposal. 1 rule, 1 evaluable with what is connected.

AgentSales practice supervision

Sales practice · The branch supervisor's suitability review: concentration against the household's own ceiling, and the trend toward it.

Running

FINRA 2111FINRA 3110

Daily. 2 rules, 2 evaluable with what is connected.

AgentSenior and vulnerable investors

Vulnerable client protection · The senior investor desk: exploitation indicators on specified adults, trusted contacts, holds on disbursements.

Running

FINRA 2165FINRA 4512

Daily. 1 rule, 1 evaluable with what is connected.

AgentRegistered representative conduct

Conduct · The registered representative conduct desk: outside business activities and private securities transactions, from what was actually written.

Running

FINRA 3270FINRA 3280

Weekly. 1 rule, 1 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.

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)

Block

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.

Confidence 100 percent. Pending a principal's disposition; Relay does not clear its own findings.

No retained copy behind a captured channel

Record completeness · SEC Rule 17a-4(b)(4), 17a-4(f)

Flag for review

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.

Confidence 100 percent. Pending a principal's disposition; Relay does not clear its own findings.

The rule set

Retail communication crossing the pre-approval threshold

FINRA · FINRA Rule 2210(a), (b)(1)

MandatoryBlock

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

MandatoryFlag for review

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)

MandatoryBlock

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)

MandatoryFlag for review

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

MandatoryBlock

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

MandatoryBlock

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)

MandatoryFlag for review

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

MandatoryFlag for review

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

Flag for review

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

MandatoryBlock

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

MandatoryBlock

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

NoteOff

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

Flag for review

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.