Gap-check an adviser AI policy against the compliance rule
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- List whether the file contains written policies, a review dated within the year, and a named chief compliance officer. Add a separate row if the policy is used in employment decisions, and a separate row for a Colorado consequential decision. Write no policy text.
- What the lawyer must review
- Rule 206(4)-7 requires written policies and procedures reasonably designed to prevent violations of the Advisers Act and its rules, a review no less frequently than annually, and a supervised person designated as chief compliance officer. The EEOC questions-and-answers state that federal employment-discrimination laws apply to AI in employment decisions, and they list protected characteristics including race, color, religion, sex, national origin, age 40 or older, disability, and genetic information. That page is about employment, not about investment advice. Colorado SB26-189 became law when the Governor signed it on 14 May 2026. The bill-page summary says developer documentation duties for covered automated decision technology start on 1 January 2027. Those duties are not in force on 22 October 2026. The signed act was not read section by section, so no section number is used. This is not an Australian regulatory guide.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Potential support includes identifying points for review. Confirm the tool’s capability and permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.