FINRA AI recordkeeping: there is no carve-out.

Published July 26, 2026 · OmniStrat AI

FINRA Regulatory Notice 24-09 makes explicit that existing books-and-records, supervision (Rule 3110), and communications rules apply fully to AI tools. Firm-built or third-party. A firm adopting AI must keep records of AI-assisted activity to the same standard as any other business record.

What Notice 24-09 actually says

FINRA's rules are technology-neutral: Rule 2210 governs AI-generated communications, Rule 3110 requires supervisory systems that account for AI reliability and accuracy, and books-and-records obligations attach to AI-assisted workflows with no exemption for new technology.

The $625 million lesson

Roughly 70 firms paid over $625M in penalties for off-channel communications, records that existed but could not be produced or trusted. AI decisioning is the next unrecorded surface: screening, scoring, research, and execution assisted by models that most recordkeeping stacks never capture.

What a firm must be able to produce

What the AI was asked, what it decided or produced, when, under whose supervision. And evidence the record was not altered. Exportable logs a vendor or the firm can rewrite do not meet the evidentiary bar an examiner applies.

Satisfying it with a proof layer

Route AI through a gateway that signs every decision to a hash-chained, externally timestamped ledger (how it works). OmniStrat produces regulator-verifiable receipts by construction, decisions via Foundry, executions via Terminal. (General information, not legal advice.)