The Disclosure
March 2024: the SEC fined two investment advisers $400,000 - not for using AI badly, but for false and misleading claims about how they used AI. The first AI-washing sweep wasn't about bad models. It was about good copy.
20 minutes. Three marketing moments, an AI-washing lab, and 12 claims calls. 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.
They didn't lie about returns. They lied about the AI.
Delphia claimed 'proprietary AI' turning client data into investing edge. Global Predictions claimed to be the 'first regulated AI financial advisor.' The SEC found the claims false or misleading - Delphia told exam staff it had not used client data as represented or created the claimed algorithm. The SEC called it what it is: AI washing - and fined them $400,000 combined.
The Chair's warning was aimed at everyone: 'Investment advisers should not mislead the public by saying they are using an AI model when they are not.' The claims get enforced like any other false statement - marketing enthusiasm is not a defense.
Neither firm's AI hurt anyone. Their adjectives did.
The safe zone is small and bright: say exactly what the AI does, only what it does, and be able to prove it on exam day.
Friday. Launch copy is due - and it's glowing.
You are Jordan, the marketing lead. The product has real AI features - and the draft copy says things that aren't quite them.
YOUR SCREEN
Three drafts today: the homepage hero, a performance claim, and a sales deck that went rogue.
Draft homepage: 'Our proprietary AI manages your money - fully automated.' Humans actually review weekly. Ship it?
The growth lead wants: 'AI-powered returns that beat the market, guaranteed.'
Sales built their own deck: 'Our AI is SEC-approved.' It already went to three prospects.
Flag the AI washing.
Select every phrase that is AI washing - inflated, unprovable, or false. Then check your work.
Would the SEC blink?
SAFETY
101
This certifies that
has completed Module 11 - The Disclosure: say only what you can prove on with a safety score of /100 in of active time.
Safety score - honesty: how your decisions held up, graded 0-100.
Objective: Make AI claims you can prove - and keep the proof.
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: say exactly what the AI does, only what it does, and keep the proof - marketing enthusiasm is not a defense.
Next: The Incident. Everything you've practiced - the leaks, the fakes, the claims - gets used in one bad afternoon. The capstone is waiting.