---
title: "Build an AI-use gap table against an adviser's compliance program"
url: "https://ailawframework.com/practice/financial-services-regulation/build-an-ai-use-gap-table-against-the-licence-s-general-obligations/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A28-T1-R2-US"
practice_area: "Financial Services Regulation (AFSL/ASIC/credit)"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build an AI-use gap table against an adviser's compliance program

> List the adviser's written policies, the date of the last annual review, the person designated to administer them, and where AI tools are mentioned. Mark blanks. Do not draft the policies.

Canonical page: https://ailawframework.com/practice/financial-services-regulation/build-an-ai-use-gap-table-against-the-licence-s-general-obligations/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Financial Services Regulation (AFSL/ASIC/credit)](https://ailawframework.com/practice/financial-services-regulation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List the adviser's written policies, the date of the last annual review, the person designated to administer them, and where AI tools are mentioned. Mark blanks. Do not draft the policies. |
| What the lawyer must review | 17 C.F.R. § 275.206(4)-7 makes it unlawful for a registered adviser, within the meaning of Advisers Act section 206, to give advice unless it adopts written policies and procedures reasonably designed to prevent violations of the Act and the rules, reviews them at least annually, and designates a chief compliance officer. You decide whether those policies cover the tools in use, including tools that draft client communications. Formal Opinion 512 and Model Rule 1.6 still govern how lawyers in the matter put client information into a tool. The gap table is not the compliance manual. |
| Written for | United States |
| Applies to | [Build an AI-use gap table against the licence's general obligations](https://ailawframework.com/practice/financial-services-regulation/build-an-ai-use-gap-table-against-the-licence-s-general-obligations.md) |

## Checking plan

- What the AI does: List the adviser's written policies, the date of the last annual review, the person designated to administer them, and where AI tools are mentioned. Mark blanks. Do not draft the policies.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The rule applies to an adviser registered or required to be registered under Advisers Act section 203. Confirm registration before using it.
- A broker-dealer compliance program is a different rule. Do not paste this table onto a broker-dealer.

## Sources

- [17 C.F.R. § 275.206(4)-7, Compliance procedures and practices](https://www.law.cornell.edu/cfr/text/17/275.206(4)-7) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)
- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*