SEC-Exam-Ready AI Governance
$12,500 fixed. The documentation package an examiner, an allocator, or your own board can open: AI use policy, supervision procedures, vendor due-diligence files, disclosure accuracy review, Reg S-P incident-response alignment, an LP DDQ answer bank, and a mock-exam walkthrough with your CCO.
Two 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. Most mid-market firms have neither document set ready.
This package is operational documentation, not legal advice. We work alongside your counsel and compliance consultants: they interpret the rules, we build the working documents and the evidence trail.
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 Package
AI use policy + supervision procedures
Approved tools, prohibited uses, data rules, human-review checkpoints, and the monitoring procedures that show supervision actually happens.
AI vendor due-diligence file, per tool
One file per AI tool in use: data handling, retention, security posture, and the review record an examiner expects to open.
Disclosure accuracy review
AI-related statements in your ADV, marketing, and LP communications, checked against what the firm actually does. The anti-AI-washing pass.
Incident-response alignment (Reg S-P)
Your incident response program extended to cover AI tools and vendors, aligned to the amended rule's detect-respond-recover-notify structure.
LP DDQ answer bank
Maintained answers to the GenAI questions now standard in allocator due diligence questionnaires, consistent with your policy and your disclosures.
Mock-exam AI 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. This package is operational documentation, not legal advice; we work alongside your counsel and compliance consultants.
Book the Package 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.
SEC AI Governance FAQ
How long does it take?
Typically two to three weeks, paced by your CCO's calendar. The heaviest item is the vendor due-diligence file set, which scales with how many AI tools are actually in use.
Is this legal advice?
No. It is operational documentation: the policies, files, and evidence trail behind the legal positions your counsel takes. We work alongside counsel and compliance consultants, and they review anything that touches interpretation.
We barely use AI. Is this premature?
If anyone at the firm touches ChatGPT, Copilot, Claude, or Gemini, you have AI use to supervise. "We don't really use AI" is a representation too, and examiners can test it against your admin consoles. Small, documented, and supervised beats informal every time.
How does this relate to the Readiness Sprint?
The AI Readiness Sprint ($8,500) is the forward-looking version: platform decision, roadmap, and a first AI policy draft. This package is the exam-grade version: supervision procedures, vendor files, disclosure review, and the mock exam. Firms that did the Sprint often add this when registration status or an exam cycle raises the bar.
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 an Exam-Readiness Gap Check
30 minutes against the 2026 priorities. You leave with a list of what is missing, whether or not you engage us.
Book the Gap CheckRelated Services
AI Readiness Sprint
Platform decision, use-case map, 90-day roadmap, and the first AI policy draft. $8,500.
Firm AI Rollout
The governance on paper, implemented in the tenant: access controls, data segregation, retention. From $25,000.
AI Operating Partner
Governance maintenance, DDQ answer bank upkeep, and vendor reviews as part of the monthly rhythm. From $10,000/mo.