AI Governance & SEC Compliance
AI governance for investment advisers, in two tiers. Tier 1, the AI Governance Framework ($9,500): an AI use policy, a supervision and monitoring approach, a vendor due-diligence framework, an LP DDQ answer bank, and a disclosure review. Tier 2, the SEC Exam-Ready Package ($12,500): everything in Tier 1 plus Reg S-P incident-response alignment, an examination-document file per AI tool, and a mock-exam walkthrough with your CCO.
AI governance for investment advisers usually arrives late. Firms adopt the tools faster than they write the rules: deal data drifts onto personal accounts, nobody has decided what is approved, and the first time anyone writes it down is when an LP DDQ or an SEC examiner asks. This puts the governance in place before the question arrives.
Two regulatory clocks ran out this year. The amended Regulation S-P took effect for advisers under $1.5 billion AUM on June 3, 2026, and the SEC's 2026 examination priorities put AI use, and the accuracy of AI claims, on the exam table. Tier 2 is built for that.
This is operational documentation, not legal advice. It is vendor-neutral across Microsoft 365 Copilot, ChatGPT Enterprise, Claude, and Gemini, and built to work alongside your counsel and compliance consultants.
Run an operating company a GP owns? This lane is for registered advisers. Portfolio companies adopting AI safely want Secure AI Adoption, and the wider Govern hub maps the rest.
By Dr. Leigh Coney, Founder of WorkWise Solutions
Two Regulatory Clocks, Both Expired
Regulation S-P, amended
The SEC's first Reg S-P overhaul in two decades requires a documented incident-response program: detect, respond, recover, notify affected individuals, and oversee the service providers that touch customer information. Larger entities had to comply by December 3, 2025. Advisers under $1.5 billion AUM hit their deadline on June 3, 2026.
Every AI tool your team uses is a service provider touching firm data. If your incident-response documentation does not account for them, it is incomplete.
FY2026 exam priorities
The Division of Examinations' 2026 priorities, released November 2025, name AI directly. Examiners will review whether firms' representations about their AI capabilities are accurate, and whether firms have adequate policies and procedures to monitor and supervise their AI use.
That cuts both ways: firms quietly using AI without supervision procedures, and firms loudly claiming AI capabilities they cannot evidence. Both show up in the same exam module.
The AI Governance Framework
The foundation any firm can stand on. Five documents your team uses day to day, an allocator reads in operational due diligence, and your CCO keeps on file. Take it on its own, or as the base of the exam-ready tier below.
AI Use Policy
Approved tools, prohibited uses, data and MNPI rules, account hygiene, and human-review checkpoints. The document that turns shadow AI into governed adoption.
Supervision & Monitoring Approach
How the firm supervises AI use in practice: what gets reviewed, by whom, and how, using the admin analytics your platform already produces.
AI Vendor Due-Diligence Framework
A repeatable way to evaluate any AI tool before it touches firm data: data handling, retention, security posture, and the input licenses that bind before the vendor's own terms do.
LP DDQ Answer Bank
Maintained answers to the GenAI questions now standard in allocator due-diligence questionnaires, consistent with the policy and ready to paste into the next DDQ.
Disclosure Review
A pass over the AI-related statements in your ADV, marketing, and LP communications, checked against what the firm actually does. The first guard against AI-washing.
The SEC Exam-Ready Package
For SEC-registered advisers, the exam-grade superset. Everything in the Tier 1 framework, plus the three additions an examiner, an allocator, or your own board can open and test.
Reg S-P Incident-Response Alignment
Your incident-response program extended to cover AI tools and vendors, aligned to the amended rule's detect-respond-recover-notify structure.
Examination-Document File, Per Tool
One due-diligence file per AI tool in use: data handling, retention, security posture, and the review record an examiner expects to open.
Mock-Exam Walkthrough with the CCO
We sit on the examiner's side of the table and ask the AI questions from the 2026 priorities. The CCO practices the answers with the documents open.
Scope note: $12,500 covers single-entity firms up to roughly 150 people. Multi-entity structures or larger firms are scoped by proposal. Like Tier 1, this is operational documentation, not legal advice; we work alongside your counsel and compliance consultants, who own the legal interpretation.
Pick the Tier That Fits
Take Tier 1, the Framework, if...
Your team already uses AI but nobody has written down what is approved or how it is supervised.
An LP DDQ asked about your AI policy and the honest answer was that you do not have one yet.
You are not a registered adviser facing an exam, so the full exam package is more than you need today.
Book Tier 2, exam-ready, if...
You are an SEC-registered adviser and your AI documentation is a Slack thread and good intentions.
An exam notice arrived, or your peers' exams started including AI questions.
Your marketing mentions AI and nobody has checked those claims against practice since they were written.
The June 3 Reg S-P deadline passed and your incident-response program predates your AI tools.
LP DDQs keep asking GenAI questions and every answer is written from scratch.
Your CCO wants a dry run before the real thing.
AI Governance & SEC Compliance FAQ
What do the two tiers cost and cover?
Two tiers. The AI Governance Framework is $9,500: an AI use policy, a supervision and monitoring approach, an AI vendor due-diligence framework, an LP DDQ answer bank, and a disclosure review. The SEC Exam-Ready Package is $12,500: everything in the framework plus Reg S-P incident-response alignment, an examination-document file per AI tool, and a mock-exam walkthrough with the CCO. The $12,500 tier covers single-entity firms up to roughly 150 people; multi-entity structures or larger firms are scoped by proposal.
Which tier do I need?
If you are not an SEC-registered adviser facing an exam, the $9,500 framework is usually enough: the rules, the supervision approach, the vendor method, and your DDQ answers. If you are registered, the $12,500 SEC Exam-Ready Package adds the evidence files and the mock exam that an examiner expects to see.
Why does AI governance matter for SEC exams in 2026?
The SEC's FY2026 examination priorities, released in November 2025, name AI directly: examiners will review whether firms' AI-capability representations are accurate and whether firms have adequate policies and procedures to supervise their AI use. Separately, the amended Regulation S-P took effect for advisers under $1.5 billion AUM on June 3, 2026, requiring a documented incident-response program. Both put AI documentation on the exam table.
How is this different from the AI Readiness Sprint?
The AI Readiness Sprint ($8,500) is the assessment: where to start, which platform, a use-case map, and a 90-day roadmap. AI Governance is the policy and supervision framework itself. Take either on its own, or both.
We barely use AI. Do we still need this?
If anyone at the firm touches ChatGPT, Copilot, Claude, or Gemini, you have AI use to supervise, and examiners may ask how. Firms that claim AI capabilities in marketing face the opposite exposure: representations that must survive an accuracy review. Either way, the documentation comes before the exam, not during it.
Is this legal advice?
No. It is operational documentation: the policy, framework, files, and answer bank your firm runs on. We work alongside your counsel and compliance consultants, who own the legal interpretation.
Who keeps it current?
You can, with the maintenance schedule we hand over. Or the AI Operating Partner retainer keeps the policy, vendor files, and DDQ answers current as tools and rules change.
Book a Governance Call
A 30-minute call to scope the framework, or the full SEC exam-ready package. You leave knowing exactly what is missing, whether or not you engage us.
Book a Governance CallThe Governance Ladder
AI Readiness Sprint
Where to start, which platform, use-case map, 90-day roadmap. $8,500.
Secure Platform Rollout
The governance on paper, implemented in the tenant: access controls, data segregation, retention. From $25,000.
AI Operating Partner
The retainer that keeps the policy, vendor files, and DDQ answers current as tools and rules change. From $10,000/mo.