FRAMEWORKS/FINANCIAL/FINRA 24-09
FINRA
FINANCIAL · FINRA

FINRA 24-09

Regulatory notice on generative AI in broker-dealers.

Regulatory Notice 24-09 (June 2024) reminds member firms that existing rules apply to generative AI: supervision (Rule 3110), recordkeeping (Rule 4511 and SEA 17a-4), communications with the public (Rule 2210), and cybersecurity. It is guidance, not a new rule, but it makes clear that AI-generated activity must be supervised and retained like any other.

AT A GLANCE
ISSUERFINRA REGIONUS broker-dealers CATEGORYFinancial CROSSWALKVersioned mapping onto the 15-control registry
EVIDENCE, NOT CERTIFICATION
01. WHO IT APPLIES TO

Is this one yours?

01FINRA member broker-dealers
02Vendors providing AI tools used in supervised activity
03Compliance teams writing AI supervisory procedures
02. KEY REQUIREMENTS

The parts of FINRA 24-09 that touch what agents do.

Rule 3110 Supervision
Firms establish and maintain a system to supervise activities, including technology-assisted ones.
Rule 4511 Books and records
Records are made and preserved in a format that prevents alteration (WORM or audit-trail equivalent).
Rule 2210 Communications
AI-assisted communications with the public are reviewed and approved as required.
Reg S-P Safeguards
Customer information is protected against unauthorized access.
03. HOW LORE MAPS TO IT

Enforcement controls, read against the requirement.

These controls exist because the platform needs them to run safely. The crosswalk reads their signed evidence against FINRA 24-09. Where there is no evidence, the report says gap.

LORE CONTROL FINRA 24-09 REFERENCE
Maker–checker approvalRule 3110 supervisory review
Signed, hash-chained receiptsRule 4511, SEA 17a-4(f) audit trail
Context disclosure recordReg S-P, Rule 2210 source review
Blocking authorization gateRule 3110(b)
Illustrative references. The shipped crosswalk carries exact clause citations, its version, and the review date.
04. OUT OF SCOPE

What Lore will not claim.

Written supervisory procedures and registered principal designations are the firm's.
Retention duration and designated third-party arrangements are governed by SEA 17a-4.
05. QUESTIONS
Is 24-09 binding?
The notice is guidance; the rules it cites are binding.
Does a receipt chain meet 17a-4?
The 2022 amendments allow an audit-trail alternative to WORM. Hash-chained, signed receipts are designed to that standard; your counsel confirms the deployment.
What about the SEC?
The SEC's proposed predictive analytics rule was withdrawn in 2025, but examination priorities continue to include AI use.
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FINRA 24-09 · EARLY ACCESSEVIDENCE COLLECTED ONCE

Start building the record your auditor will read.

Every receipt Lore signs today is evidence for FINRA 24-09 tomorrow. Turn the crosswalk on when you are ready; nothing needs re-collecting.

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