THE SIGNAL
On December 9, 2025, FINRA published its 2026 Annual Regulatory Oversight Report, with a new section, GenAI: Continuing and Emerging Trends. It reminds firms that "Pursuant to FINRA Rule 3110 (Supervision), a member firm must have a reasonably designed supervisory system tailored to its business."
The report calls out AI agents as an emerging trend. Among the risks it lists: "Autonomy: AI agents acting autonomously without human validation and approval." And: "Scope and Authority: Agents may act beyond the user's actual or intended scope and authority."
Among effective practices, FINRA describes "Implementing formal review and approval processes to assess and evaluate GenAI opportunities and the necessary controls to help manage unique risks, including both business and technology experts." For agents, it suggests firms consider "how to track agent actions and decisions."
BEFORE
Hypothetical: a wealth management team at a broker-dealer wants to pilot an agent that drafts client meeting prep for financial advisors. The scope is written, the data access is limited, the human review step is defined, and compliance has signed off on the supervisory procedures.
The firm's GenAI review committee has to approve the pilot. It meets monthly, and this month's agenda is full. The chief compliance officer and the head of the wealth business could approve it between meetings, but no one has written down that they may.
The file is ready. The person who can release it is not.
WHAT THE WAIT COSTS
The pilot waits a month for a slot, then waits again if the committee has a question no one can answer in the room. Meanwhile, advisors keep using whatever informal tools they already have, outside the controls the pilot was designed to put in place.
AFTER
The committee writes its own delegation: pilots within defined limits (scope, data access, human review, logging of agent actions) can be approved by two named officers between meetings, with the full committee reviewing the record afterward.
The pilot packet goes to both officers with the scope, the controls and the open risks. They approve it in a day, the reasons are recorded, and the committee sees the decision at its next meeting.
HOW WISDOMTWIN FITS
WisdomTwin.ai is building a sovereign judgment layer for regulated enterprises. It is designed to give each named approver a role-specific judgment twin that prepares the decision packet the way that person reviews, with the evidence attached, so the decision moves faster and leaves an auditable record. It is designed to run on-premises, on-device or in your private cloud, and the named person still makes the call.
We don't replace judgment. We remove the wait.
TRY THIS THIS WEEK
Count the GenAI and agent proposals waiting on your review committee, and how long the oldest has waited.
Write down which kinds of pilots could be approved between meetings, and by whom.
Check that every approved agent has a record of its actions and decisions that a supervisor can review.
SOURCES
FINRA, 2026 FINRA Annual Regulatory Oversight Report, December 9, 2025: FINRA 2026 Annual Regulatory Oversight Report
FINRA, GenAI: Continuing and Emerging Trends (2026 report section): FINRA GenAI: Continuing and Emerging Trends
Examples in this issue are hypothetical, and nothing here describes a customer result.
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Roman Bodnarchuk
Co-Founder and CEO, WisdomTwin.ai