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Audit Trail

Firmly maintains a complete, tamper-evident record of every AI interaction with investment data. When analysts use AI to query deal documents, summarize portfolio performance, or retrieve market research, each action is automatically logged with full context—who accessed what, when, and why.

Why Audit Trails Matter in Investment Management

SEC Rule 204-2 requires investment advisers to maintain books and records of their business activities. When AI becomes part of your investment process, those interactions become part of your recordkeeping obligations. Beyond regulatory compliance, comprehensive audit trails serve critical functions:

  • SEC examination response — Demonstrate exactly what information your team accessed and when investment decisions were made
  • Investor due diligence — Provide institutional investors with evidence of your operational controls
  • Internal compliance — Review how analysts are using AI assistance to ensure appropriate use of material non-public information
  • Litigation defense — Trace the sequence of events when responding to investor disputes or regulatory inquiries

What Gets Logged

Every AI interaction with investment data captures:

  • Who — The analyst or portfolio manager who initiated the query
  • What — The deal documents, portfolio data, or research accessed
  • When — Precise timestamp of the interaction
  • Context — The fund, deal team, and conversation where access occurred
  • Outcome — Whether the query succeeded and what information was returned

Tamper-Evident Integrity

Firmly uses cryptographic chaining to ensure audit records cannot be altered without detection. Each log entry is mathematically linked to the previous entry, creating an unbroken chain that proves:

  • No entries have been deleted
  • No entries have been modified after the fact
  • No entries have been inserted out of sequence

This integrity verification is essential when presenting audit logs to SEC examiners, external auditors, or in legal proceedings. You can demonstrate with certainty that the records accurately reflect what occurred.

Long-Term Preservation

When audit logs reach their retention limit, they are archived before deletion. This preserves the ability to verify the integrity chain historically—critical for responding to SEC examinations or litigation that may span years after the original investment activity.

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