The Record
Since December 2021 the SEC's off-channel initiative has charged 100+ firms - more than $2 billion in penalties - not for what they said, but for failing to maintain and preserve required business communications. Meanwhile, your AI note-taker would like to 'optimize storage.' Adorable. Also expensive.
20 minutes. Three retention calls, a records audit, and 12 filing decisions. A safety score that follows you.
Before you start
- One real incident, played as decisions - no slides, no lectures.
- About 20 minutes, one sitting - leave early and you start over.
- You make timed choices; your score changes with your decisions.
- You get a safety score with feedback on every decision - never a leaderboard, never your name.
- Your firm sees completion evidence - never your answers. Teammates never see your score.
- Finish and you get a certificate with a unique ID anyone can verify.
Free for everyone. All 18 drills are free - finish and you get a verifiable certificate.
The AI wrote it. You own it. Keep it.
The SEC's off-channel sweeps charged more than 100 firms - over $2 billion - for business done on personal texts and WhatsApp. No fraud required: the missing records were the violation. The lesson landed hard: retention duties follow the content, not the app - a required record stays a required record off-channel.
Then FINRA Notice 24-09 (June 2024) said the quiet part out loud: existing supervision, recordkeeping, and communications rules already apply to generative AI. If it's a required record when a person writes it, it's a required record when AI writes it. The robot does not come with a loophole.
The trap: AI tools default to deleting, summarizing, and 'optimizing storage.' Cute feature. Terrible legal strategy. Your retention schedule comes from the rulebook, not the settings page.
Wednesday. Your AI note-taker wants to 'optimize' the archive.
You are Rey, the compliance officer. The firm records client calls, files AI summaries, and the note-taker just made a suggestion with real 'trust me' energy.
YOUR SCREEN
Three calls today: what happens to the raw transcript, an auto-delete 'feature,' and an AI-made testimonial marketing loves.
An advisor files the AI summary of a client call and deletes the raw recording. Clean, right?
The note-taker offers: 'auto-delete transcripts after 30 days to save storage.' The vendor pre-checked the box, naturally.
Marketing built a 'client testimonial' with AI, stitched from real reviews. Ship it?
Flag what breaks the record book.
Select every item that is a record mishandled - must be kept but isn't, or client-facing without supervision. Then check your work.
Make the retention call.
SAFETY
101
This certifies that
has completed Module 9 - The Record: AI doesn't change the recordkeeping rule on with a safety score of /100 in of active time.
Safety score - evidence: how your decisions held up, graded 0-100.
Objective: Document AI-assisted decisions to an evidence standard.
Seat time ~10-25 minutes. Verify this certificate at aisafety101.com/verify.
Evidence on record: module completion, seat time, final score, and certificate ID. This certificate ID verifies in your firm's admin report. A team certificate issues when every enrolled employee completes the full curriculum.
Your one rule to keep: AI creates no recordkeeping loophole - if AI-assisted content falls in a required record category, preserve it, supervise it, and be able to produce it.
Next: The Vendor. Zoom's AI terms sat unnoticed for months - then one read sparked a public backlash and a rewrite within days. Your approved tools are shipping AI features this quarter - and their terms are moving under you. Module 10 is waiting.