Meeting transcripts are the latest features to be added to communication platforms such as Microsoft Teams and Zoom. Compliance Officers must assess the benefits and risks to their organizations.
In a recent forum on the National Society of Compliance Professionals (“NSCP”), we advised that transcripts (as well as meeting recordings) should be archived separately from the regulatory compliance content of chats and attachments. Adding transcripts (Microsoft’s Teams Copilot or Zoom’s AI Companion) onto a compliance record subjects a financial institution to content that may not be accurate and is not required by either SEC Rule 17a-4(b) or Rule 204-2(a). Though content generated from an application is not a regulatory communication, it becomes such if subsequently forwarded to a client. However, in this case, it will be preserved in the institutional email archive.
“Separating non-regulatory content from regulatory content requires that a firm have capture software that identifies the type of content. In our DataParser software, we separate transcripts from chats and attachments but then insert a link into the regulatory content. This allows a reviewer to easily click on a link to access the non-regulatory content, which may be retained in Azure, AWS, SharePoint, or another platform. We then advise clients to have a separate retention policy for non-regulatory content which may be as short as 30 days.” says Charles Weeden, Managing Partner.
AI continues to incorporate more functions within an organization, including composing messages, suggesting content or investments, integrating data from other databases, and generating task lists or summaries. Compliance officers must be ever-wary as to when a new offering crosses the line and becomes regulatory content.
Meeting Compliance – 17a-4 LLC Compliance Services | SEC FINRA Regulatory Compliance
