---
title: "Check whether AI-drafted advice has a human review step"
url: "https://ailawframework.com/practice/financial-services-regulation/gap-check-an-afsl-holder-s-ai-governance-against-asic-rep-798/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A28-B1-1-US"
practice_area: "Financial Services Regulation (AFSL/ASIC/credit)"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Check whether AI-drafted advice has a human review step

> Record whether the written policies mention review of advice generated with a tool, the date of the latest annual review in the file, and the name of the designated compliance officer. Write no policy text.

Canonical page: https://ailawframework.com/practice/financial-services-regulation/gap-check-an-afsl-holder-s-ai-governance-against-asic-rep-798/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 | Record whether the written policies mention review of advice generated with a tool, the date of the latest annual review in the file, and the name of the designated compliance officer. Write no policy text. |
| What the lawyer must review | This is not an Australian regulatory-guide gap check. Rule 206(4)-7 requires written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules under it, a review no less frequently than annually, and a supervised person designated to administer the policies. Formal Opinion 512 still requires a lawyer to verify generative output. The tool records what the file contains. The lawyer decides whether the policies are adequate. |
| Written for | United States |
| Applies to | [Gap-check an AFSL holder's AI governance against ASIC REP 798](https://ailawframework.com/practice/financial-services-regulation/gap-check-an-afsl-holder-s-ai-governance-against-asic-rep-798.md) |

## Checking plan

- What the AI does: Record whether the written policies mention review of advice generated with a tool, the date of the latest annual review in the file, and the name of the designated compliance officer. Write no policy text.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- A missing step in the file is a question, not a finding of a violation.
- Do not put client portfolios into a public tool.

## Sources

- [17 C.F.R. section 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 1.1, Competence](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_1_competence/) (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.*