meilynx_

Framework · Broker-dealer

FINRA 24-09 for generative AI.

FINRA Regulatory Notice 24-09 makes the point plainly: the rules you already follow — supervision, recordkeeping, communications — apply to generative AI. Meilynx is how you extend those controls to AI without standing up a parallel stack.

What 24-09 reminds firms

Existing rules, applied to AI.

The notice doesn't invent obligations — it reaffirms that supervision, books-and-records, and communications rules reach your use of generative AI. The work is making AI activity supervisable and on the record.

  • Supervision of AI use under Rule 3110.
  • Recordkeeping of AI activity under Rule 4511 / SEA 17a-4.
  • Communications review under Rule 2210 for AI-generated content.
  • MNPI and model risk managed as the notice highlights.
How Meilynx maps

Each rule, to a control.

The specific Meilynx control for each rule 24-09 points to — and the record it produces.

FINRA 24-09 → Meilynx controls

Supervise the use of generative AI

FINRA Rule 3110

Maps to · Policy-as-code enforces what AI may and may not do, inline; governance findings and a review surface give supervisors a reviewable record of AI activity.

Examination artifact · Supervisory policy + findings log

Make and preserve books and records

FINRA Rule 4511 · SEA 17a-4

Maps to · Every AI request and decision is written to a WORM audit store with a 6-year retention floor and a tamper-evident hash chain — recordkeeping built for the regulatory floor.

Examination artifact · WORM audit trail · 6-yr retention

Supervise communications with the public

FINRA Rule 2210

Maps to · Output controls — safety scans and content rules — screen AI-generated text before it returns, so communications stay within policy.

Examination artifact · Output-control findings

Protect material non-public information

Information barriers

Maps to · MNPI detection flags or blocks material non-public information before it reaches a model or leaves in a response, attributable to the team involved.

Examination artifact · MNPI findings, by team

Manage model and vendor risk

Reg Notice 24-09

Maps to · An auto-populated model inventory and a per-customer isolated data plane address the model- and third-party-risk themes the notice raises.

Examination artifact · Model inventory + isolation record

The examination artifact

Books and records, ready.

The audit trail renders into a package aligned to the FINRA reflex — a supervisable record of AI activity, communications findings, and a WORM-backed history retained to the regulatory floor.

In the package

  • Supervisory policy snapshot and review findings.
  • Communications (Rule 2210) output-control findings.
  • Model inventory drawn from live traffic.
  • WORM audit trail, 6-year retention, SHA-256 integrity hash.
FAQ

24-09 and AI.

Does FINRA 24-09 create new rules for AI?

No. Regulatory Notice 24-09 (2024) reminds firms that FINRA's existing rules — supervision, recordkeeping, communications, and others — already apply when firms use generative AI. The obligation is to extend those existing controls to AI tools, not to follow a separate AI rulebook.

How does Meilynx satisfy the recordkeeping requirement?

AI activity is written to a write-once, read-many audit store with a 6-year retention floor — aligned to the FINRA Rule 4511 and SEA 17a-4 expectations — and sealed in a tamper-evident hash chain so the record is examiner-verifiable.

Can supervisors actually review what the AI did?

Yes. Because enforcement happens inline, every governed AI interaction lands in the audit trail with the policy decision attached. Supervisors get a reviewable record of AI activity rather than reconstructing it after the fact.

Examination package

See exactly what an examiner receives

Download a sample examination package — model inventory, control coverage, a governance policy snapshot, and a SHA-256 integrity hash.