By: E.J. Yerzak and Adam DiPaolo
Introduction
Artificial intelligence has been a game-changer for financial institutions through tools such as virtual notetakers, advanced prompts for investment screening and modeling, automation of contract review, and more. Powerful AI-driven applications have introduced incredible operational efficiencies, performing routine and repetitive tasks in a fraction of the time that their manual counterparts would take. Investment advisers seem to be dipping their toes in the AI waters with one use case more frequently than any other – the use of AI notetakers. But using AI notetakers in a compliant and secure way is no small task.
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Understanding The Use Cases
Notetakers are a specific category of AI tools that can capture audio-visual information from a virtual or in-person meeting and generate a written transcript of the meeting. Further AI analysis can then organize and summarize the meeting into key bullets and action items. Transcripts can be stored for subsequent queries to enable quick retrieval, enabling lightning-fast answers to questions such as “When was the last time our team discussed the technology sector with this client?” or “How has the client’s sentiment about the market changed over the last twelve months?” AI can find those answers much faster than a person can. And with the addition of AI agents and APIs into other systems, the action items from a meeting can be fed directly into tasks within a CRM, for example.
There are numerous AI transcription tools in existence. Zoom, Teams, Jump, Fireflies and Otter AI are just a few of the vendors currently offering AI notetaking and transcription capabilities. Having AI transcribe a meeting allows financial advisors and representatives more freedom to participate and remain attentive to the client without the need to jot down every note. AI notetakers also save significant time for colleagues who were not able to participate in the meeting, allowing them to catch up quickly on the topic discussed by scanning the key bullets generated from the transcript.
Capturing, transcribing, and organizing information from a meeting is arguably one of the most useful ways AI is being incorporated into the day-to-day operations of registered investment advisers. These notetakers are increasingly ubiquitous attendees in videoconferencing meetings with clients, internal meetings, and even expert network calls. Before using AI notetakers, however, advisers should understand the legal, compliance, and cybersecurity implications.
Attendant Risks
The use of these AI notetakers can raise material consent, compliance and cybersecurity risks.
- Consent Issues:
- Conflicting State Law
- Technical Implications
- Meetings Involving Third Party Organizations
- Compliance Issues:
- Books and Records Retention
- Cybersecurity Issues:
- Disclosure of Personally Identifiable Information
- Vendor Due Diligence
Practical Tips for Using AI Transcription Tools
Advisers may find the following tips helpful in creating and monitoring a compliance framework for the use of AI Notetakers by their colleagues:
- Create an AI policy setting forth the specific requirement for advisory personnel to review the accuracy of any AI-generated content, including meeting transcriptions, prior to subsequent use of such content. There should always be an element of review by a human whenever AI is involved. Although the accuracy of AI transcriptions continues to improve, the technology is not foolproof and transcription errors can occur. The tone and context for jokes and other comments made during verbal meetings aren’t always apparent in a written transcript alone.
- As an alternate or additional approach, consider adding a disclaimer at the top of an AI transcript before saving it in your files. Some organizations are including language stating that the transcript has been generated automatically by AI and may not be an accurate or complete representation of what was discussed. While this approach helps to mitigate accuracy risk, the disclosure alone may not prevent downstream use of the transcript and its contents by your firm or its applications in the future. Therefore, firms are still advised to review transcripts for accuracy before saving them.
- Confirm all attendees to an AI-recorded and transcribed meeting consent to that recording. As a practical matter clients and/ or meeting participants with the knowledge of AI usage in this setting may or may not want to share certain information.
- Establish and communicate policies regarding the granting of consent for recordings by external parties. The investment adviser may not be the only party interested in leveraging AI for meeting transcriptions. Clients, consultants, and other parties may also seek to record meetings in which your firm participates. The policies should make clear that your firm does not retain or control the storage or use of such recordings by third parties. Consider allowing your staff to exercise their own professional judgment for granting consent to a third party’s use of AI transcription depending upon the nature and context of the meeting and what will likely be discussed.
- Establish procedures for where AI-generated transcripts will be retained and for how long.
- For customized assistance in developing your AI procedures, as well as any questions relating to AI use cases, AI vendor due diligence, and prompt engineering optimization, contact Salus GRC for more information about our AI Consulting Services