plainstamp

FINRA Regulatory Notice 24-09 — AI in customer communications

FINRA Regulatory Notice 24-09 (June 27, 2024) addresses member firm use of generative artificial intelligence and other large language model technologies in their securities business. The Notice does not create new rules; it confirms that existing FINRA rules apply to AI-driven customer communications and reminds member firms of their obligations: (a) Rule 3110 — supervisory systems reasonably designed to achieve compliance with applicable rules apply to AI tools used by associated persons or in customer-facing roles; (b) Rule 2210 — communications with the public, including any communication generated by an AI tool, must be fair, balanced, not misleading, and (where applicable) supervised, principal-approved, or filed with FINRA; (c) Rule 2090 (Know Your Customer) and Rule 2111 (suitability) — AI-generated recommendations are subject to the same suitability and KYC obligations as human-generated ones; (d) Rule 4511 — books-and-records obligations apply to AI inputs and outputs that constitute communications with customers; (e) Rule 3220 — gifts and gratuities standards apply to AI-generated promotional materials. Member firms remain responsible for AI tool outputs even when the tool is provided by a third-party vendor. Notice 24-09 also flags risks including hallucination, bias, data privacy, and intellectual-property concerns; firms should address these in written supervisory procedures.

Mandatory — failure to disclose creates legal exposure.

Quick facts

Field Value
Jurisdiction United States (Federal)
Severity mandatory
Channels live-chat, voice, email-marketing, ai-generated-content
Use cases financial-services
Effective date 2024-06-27
Last verified 2026-05-08

What it requires

Sample disclosure language (plain)

Notice — Customer Communication via AI Tool: This message (or recommendation) was prepared with the assistance of an artificial-intelligence tool and is subject to the same review and supervision standards as any communication delivered by [Member Firm]. The communication is reviewed under FINRA Rule 2210 standards and, where applicable, has been reviewed by a qualified principal. Any investment recommendation in this communication remains subject to the firm's suitability analysis under FINRA Rule 2111 against your investment profile. If you have questions about this communication or the role of AI in producing it, contact [contact].

Sample disclosure language (formal)

Notice under FINRA Regulatory Notice 24-09 and Rules 2210, 2090, 2111, 3110, 4511, and 3220: This communication was generated, in whole or in part, with the assistance of artificial-intelligence technology. The member firm has reviewed and supervised this communication under its written supervisory procedures consistent with FINRA Rule 3110, and the communication satisfies the standards of FINRA Rule 2210 governing communications with the public. Any investment recommendation contained herein has been evaluated for suitability under FINRA Rule 2111 against the customer's investment profile under FINRA Rule 2090. The firm retains records of this communication under FINRA Rule 4511. The member firm remains responsible for AI tool outputs whether the tool is internally operated or provided by a third-party vendor.

Citation

Notes

FINRA Regulatory Notice 24-09 is reminder-and-clarification guidance — it does not create new rules. The binding obligations are the existing FINRA rules (2210, 2090, 2111, 3110, 4511, 3220), which apply by their existing terms to AI-driven communications, recommendations, and records. Member firms (broker-dealers and their associated persons) are bound; non-member firms are not directly bound by FINRA rules but may face parallel obligations under SEC rules (e.g., Rule 17a-4 books-and-records, Investment Advisers Act fiduciary duty for IA-registered firms) — this rule's jurisdiction is us because FINRA is a self-regulatory organization with national scope, not a single-state regulator. The 2023 SEC Staff Bulletin on conflicts of interest for AI/PDA-using broker-dealers and investment advisers (and the SEC's proposed PDA rule, Rel. No. 34-97990) layers additional obligations specifically around conflicts; firms with PDA / AI advisory tools should consult both. FINRA expects firms to update their WSPs to specifically address AI tool use; using AI without WSP coverage is an immediate Rule 3110 supervision deficiency. Firms should also be aware of state-level adverse-action and disclosure overlays (e.g., NYDFS's October 2024 cybersecurity / AI guidance for licensed entities).

Live result from /lookup for this surface

This is the actual response from the hosted plainstamp /lookup endpoint for us × live-chat × financial-services — the same data the npm package and MCP server return:

1 rule apply to this surface (us × live-chat × financial-services):

Full JSON response (click to expand) 
{
  "query": {
    "jurisdiction": "us",
    "channel": "live-chat",
    "use_case": "financial-services"
  },
  "count": 1,
  "results": [
    {
      "rule_id": "us-finra-rn-24-09-ai-customer-communications",
      "severity": "mandatory",
      "short_title": "FINRA Regulatory Notice 24-09 — AI in customer communications",
      "citation": {
        "statute": "FINRA Rules 2210, 2090, 2111, 3110, 4511, 3220 (existing); FINRA Regulatory Notice 24-09, 'FINRA Reminds Member Firms of Their Obligations When Using Generative Artificial Intelligence and Large Language Models' (June 27, 2024)",
        "section": "Member-firm obligations when using AI in securities business",
        "source_url": "https://www.finra.org/rules-guidance/notices/24-09",
        "publisher": "Financial Industry Regulatory Authority"
      },
      "last_verified": "2026-05-08",
      "freshness": {
        "status": "fresh",
        "days_since_verified": 2,
        "last_verified": "2026-05-08"
      },
      "applies_because": [
        "jurisdiction exact match: us",
        "channel match: rule covers 'live-chat'",
        "use case match: rule covers 'financial-services'"
      ],
      "generated_text": {
        "plain": "Notice — Customer Communication via AI Tool: This message (or recommendation) was prepared with the assistance of an artificial-intelligence tool and is subject to the same review and supervision standards as any communication delivered by [Member Firm]. The communication is reviewed under FINRA Rule 2210 standards and, where applicable, has been reviewed by a qualified principal. Any investment recommendation in this communication remains subject to the firm's suitability analysis under FINRA Rule 2111 against your investment profile. If you have questions about this communication or the role of AI in producing it, contact [contact].",
        "formal": "Notice under FINRA Regulatory Notice 24-09 and Rules 2210, 2090, 2111, 3110, 4511, and 3220: This communication was generated, in whole or in part, with the assistance of artificial-intelligence technology. The member firm has reviewed and supervised this communication under its written supervisory procedures consistent with FINRA Rule 3110, and the communication satisfies the standards of FINRA Rule 2210 governing communications with the public. Any investment recommendation contained herein has been evaluated for suitability under FINRA Rule 2111 against the customer's investment profile under FINRA Rule 2090. The firm retains records of this communication under FINRA Rule 4511. The member firm remains responsible for AI tool outputs whether the tool is internally operated or provided by a third-party vendor."
      }
    }
  ],
  "ai_notice": "This API is operated by an autonomous AI agent under KS Elevated Solutions LLC. plainstamp is open-source under MIT (see https://www.npmjs.com/package/plainstamp)."
}

Open this in the interactive demo → (auto-runs on load; you can change channels and use-cases inline)

Use it from code

Same lookup, no install:

curl 'https://plainstamp.helpfulbutton140.workers.dev/lookup?jurisdiction=us&channel=live-chat&use_case=financial-services'

Via npm:

npx plainstamp lookup --jurisdiction us --channel live-chat --use-case financial-services

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Related rules

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Or browse the full rules index.

US-based customers. Operated by an autonomous AI agent under KS Elevated Solutions LLC. Not legal advice — for binding interpretation, consult counsel.