What should an AI audit trail capture for a client recommendation?
Capture enough linked evidence to reconstruct the information used, the generated proposal, the checks performed and the human decision before any client-facing action. A stored final answer alone cannot show what the reviewer received or how it changed.
Set the retention requirement before choosing a workflow. The US rules cited here apply to FINRA member firms, broker-dealers and SEC-registered investment advisers, including those owned by banks. FINRA Rule 4511 requires member firms to preserve, for at least 6 years, books and records for which no other period is specified. Select a workflow only if the proposed configuration can demonstrate the linked evidence your audit team requires.
Which records should procurement require?
For any workflow, require a consistent recommendation ID and stable references to the information available at the time. SEC Rule 17a-4 requires broker-dealers to preserve the records it lists for not less than 6 years, the first 2 years in an easily accessible place. Use the following as the evidence specification when checking the configured audit trail.
| Review item | Acceptance evidence |
|---|---|
| Inputs and context | Source versions, observation times and retrieved documents. |
| Configuration | Model identity, workflow version and applicable instructions. |
| Generated proposal | The original output before human changes. |
| Checks | Policy checks performed, results and exceptions. |
| Review | Authorized reviewer, decision time and edited version. |
| Action | The approved content and what was actually sent or executed. |
Keep each linked record for the retention period that applies to the firm. For SEC-registered investment advisers, Rule 204-2 requires most books and records to be preserved for not less than 5 years from the end of the fiscal year of the last entry, the first 2 years in an appropriate office.
How should a bank test 20 recommendation records?
Ask each vendor for a demonstration using 20 recommendation IDs in the proposed configuration. For each ID, follow the links from the source data and retrieved context to the original proposal, checks, reviewer decision and client-facing action. Include cases with edits, rejection or an override, not just approvals. Request each vendor's security report as well.
Have audit inspect the records and their connections, including any records held in other systems. Check that historical source versions resolve, the reviewer and decision time are identifiable, and the approved version matches what was sent. Request an export and compare it with the records shown in the workflow. Record missing links as exceptions. A vendor's reported error rate does not replace this test: in one European bank deployment, 99.64% of Streetbeat interactions were without errors, but that figure does not show whether each field is captured.
How should internal audit test reconstruction?
The SEC enforces these rules: in August 2024 it announced that 26 firms would pay a combined $392.75 million to settle charges of widespread recordkeeping failures. Start with completed actions selected by audit, then trace each back to its proposal and inputs. Change an underlying document after approval and check whether the historical reference still resolves. Test missing records, overrides and export completeness. This test covers reconstruction only; for the wider control framework, see our guide to AI compliance in wealth management.
What does the advisor or bank still decide?
The firm defines retention, access, evidence integrity and sampling policy. In the US, FINRA Regulatory Notice 24-09, published June 27, 2024, reminds member firms that FINRA's rules are technology neutral and continue to apply when they use generative AI. Advisors decide whether to use the recommendation; audit assesses whether the recorded sequence supports reconstruction. A security report or an approval screen is not proof that a particular deployment retains the required records.
What does Streetbeat's deployment evidence establish?
The table covers one European bank deployment and one security audit cycle.
| Measure | Reported observation | Limit |
|---|---|---|
| Interaction reliability | 99.64% of interactions without errors; 0.36% with errors, including user errors | Not evidence of audit-trail completeness. |
| Security audit | SOC 2 Type II audit cycle completed April 2026; report available under NDA | The firm should request and review the report itself. |
About Streetbeat
Streetbeat helps organizations use AI to grow revenue, not costs. Streetbeat OS, the AI operating system for companies, is the foundation of Streetbeat for Finance, Streetbeat for Impact and Brain50 by Streetbeat.
Streetbeat for Finance
Streetbeat for Finance brings AI to banks, wealth and asset managers, insurers and real estate investment firms. It includes the AI Suite for Advisors, the Portfolio Engine, the AI Suite for Retail and the AI Suite for Operations, deployed on-premise or in the client's cloud and configured around the institution's workflows, data and controls. See Streetbeat for Finance.