Framework · Broker-dealer
FINRA 24-09 for generative AI.
FINRA Regulatory Notice 24-09 makes the point plainly: the rules you already follow on supervision, recordkeeping, and communications apply to generative AI. Meilynx is how you extend those controls to AI without standing up a parallel stack.
Existing rules, applied to AI.
The notice 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.
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
| Requirement | How Meilynx maps | Examination artifact |
|---|---|---|
Supervise the use of generative AI FINRA Rule 3110 | 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. | Supervisory policy + findings log |
Make and preserve books and records FINRA Rule 4511 · SEA 17a-4 | Each AI request and decision is written to a WORM audit store with a 6-year retention floor and sealed in a tamper-evident hash chain. | WORM audit trail · 6-yr retention |
Supervise communications with the public FINRA Rule 2210 · Rule 3110 | AI-generated communications are routed to a supervisory review queue with two-party approval, and every request and response is preserved in the WORM record with an append-only decision history. | Supervisory review decisions · WORM archive |
Protect material non-public information Information barriers | MNPI detection flags or blocks material non-public information before it reaches a model or leaves in a response, attributable to the team involved. | MNPI findings, by team |
Manage model and vendor risk Reg Notice 24-09 | An auto-populated model inventory and a per-customer isolated data plane address the model- and third-party-risk themes the notice raises. | Model inventory + isolation record |
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 · Each AI request and decision is written to a WORM audit store with a 6-year retention floor and sealed in a tamper-evident hash chain.
Examination artifact · WORM audit trail · 6-yr retention
Supervise communications with the public
FINRA Rule 2210 · Rule 3110
Maps to · AI-generated communications are routed to a supervisory review queue with two-party approval, and every request and response is preserved in the WORM record with an append-only decision history.
Examination artifact · Supervisory review decisions · WORM archive
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
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.
- Supervisory review decisions and approval history (Rule 2210 / 3110).
- Model inventory drawn from live traffic.
- WORM audit trail, 6-year retention, SHA-256 integrity hash.
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 on supervision, recordkeeping, communications, and more 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. The record is sealed in a tamper-evident hash chain so an examiner can verify it.
Can supervisors actually review what the AI did?
Yes. Because enforcement happens inline, each governed AI interaction lands in the audit trail with the policy decision attached. Supervisors review a record of AI activity that already exists; nothing has to be reconstructed after the fact.
Build the evidence.
See exactly what an examiner receives
Request a sample examination package: model inventory, control coverage, a governance policy snapshot, and a SHA-256 integrity hash.