Is this investment advice?

No. Serra Education provides process and tooling consulting only, never Serra Wealth investment advice. What you get here is a process-and-governance guide, not legal, investment, or compliance advice. Use it to structure your own decisions, and confirm every obligation against the primary source and your own counsel.

The blocker isn't the model — what is it?

It is the audit trail. Most wealth firms have already tried AI somewhere. Far fewer can show a reviewer where the data went, who checked the output, and how the decision would be reconstructed if a regulator asked. The binding constraint sits in the workflow around the model, not in the model you pick.

Do these obligations change if I switch AI tools?

No. None of the rules regulate which model you use. They regulate whether a human owns the output, whether client data stays contained, whether client-facing AI is disclosed, and whether you can reconstruct what the model did. A firm can swap one model for another and change nothing about its compliance position.

Where do the finder briefings come from?

Primary law, read by a person. Each obligation is sourced to the actual article, MiFID II, the GDPR, the EU AI Act, the FCA Handbook, ICO guidance, not to a scraped summary. Every line carries a citation and a confidence badge, and a person reviews each briefing before it is published.

How does the paid path work, and what does it cost?

It is three steps, in order, and the paid step is never first. Start with a free one-page report for your firm. Then a free 15-minute intro call. If it is useful, a 60-minute optimisation session is 250 EUR, and that fee credits in full toward a Tier 1 audit, which runs 2,000 to 10,000 EUR depending on firm size and the number of workflows in play.

Can I put live client data into an AI tool to test this?

Do not. Keep live client data out of any general-purpose AI tool. The report on this page is produced from a prompt you run inside your own environment, no client data leaves you, and Serra never asks you to send client data. Any real-data workflow needs a contracted tool, a lawful basis, and a data-protection impact assessment first.

Is Serra vendor-neutral?

Yes. Serra Education does not resell an AI stack, so the recommendation is what works in your firm, not what pays a referral. The engagement is about the governance around the model, which is portable across whichever tools you already run.

AI compliance obligations for an IFA / RIA in the US

4 AI-adoption compliance obligations apply, each cited to primary law.

Keep the records of advice the AI helps produce

Rule: Advisers Act Rule 204-2 (Books & Records)

What it requires: A registered investment adviser must make and keep true, accurate and current books and records relating to its advisory business, including recommendations and client communications. Output an AI tool drafts or supports is part of that advisory record.

Do this: Log which AI tool was used, on what input, and who reviewed it, retained with the client's advisory file for the required period, so the record is complete with or without a model in the loop.

Source: Investment Advisers Act of 1940, Rule 204-2 (17 CFR 275.204-2).

Confidence: Verify

Adopt written policies governing your AI use

Rule: Advisers Act Rule 206(4)-7 (Compliance)

What it requires: An adviser must adopt, implement and annually review written policies and procedures reasonably designed to prevent Advisers Act violations. Introducing AI into advisory workflows is a change those policies must address.

Do this: Add AI governance — approved tools, human-review checkpoints, data handling, testing — to your compliance manual and cover it in the annual review.

Source: Investment Advisers Act of 1940, Rule 206(4)-7 (17 CFR 275.206(4)-7).

Confidence: Verify

AI in the advice chain does not move your fiduciary duty off the firm

Rule: Advisers Act fiduciary duty (Section 206)

What it requires: An investment adviser owes a fiduciary duty of care and loyalty to its clients; the SEC's 2019 interpretation confirms a recommendation must be in the client's best interest. Where AI contributes to a recommendation, the adviser remains fully responsible for the advice given.

Do this: Keep a named adviser accountable for any recommendation an AI tool helped shape, and document the basis for the advice so the best-interest standard is evidenced.

Source: Investment Advisers Act of 1940, Section 206; SEC Commission Interpretation Regarding Standard of Conduct for Investment Advisers (Release IA-5248, 2019).

Confidence: Verify

Have an incident-response program and meet the breach-notice timeline

Rule: Regulation S-P (Release 34-100155)

What it requires: Under the Regulation S-P amendments adopted 15 May 2024, SEC-registered advisers must maintain a written incident-response program and notify affected individuals of a breach of sensitive customer information as soon as practicable and no later than 30 days. Client data entering AI tools falls within this duty.

Do this: Bring any AI tool that touches customer information inside your Reg S-P safeguards and incident-response program, and confirm your breach-notice process meets the 30-day deadline.

Source: SEC Release No. 34-100155 (Regulation S-P amendments, adopted 15 May 2024); 17 CFR 248.30.

Confidence: Verify