For compliance
You are not the objection. You are the buyer.
Every rule below has a named owner on the team and a piece of evidence you can open. Your team reviews a finished, traceable answer, not a blank page.
Built for registered investment advisers, broker-dealers and dually registered firms, wealth and asset managers, bank and trust wealth divisions, and the hybrid RIA platforms that supervise all of the above.
The rules
Your obligations, who handles each, and what you can check.
Named rules, mapped to named behavior. We state what the system is aware of and designed for, and nothing beyond that.
FINRA 2210
SentinelCommunications with the public
Sentinel reviews every client document Draft writes against 2210, returns required edits, and re-reviews until it accepts or escalates to your compliance team.
Your evidence
A verdict on the exact text that ships, with each finding tied to its sentence and rule.
SEC Marketing Rule
SentinelProspect materials
Fair-and-balanced review and required disclosures on prospect and marketing content, scoped to the kind of communication it is, before anything is packaged.
Your evidence
Required edits and disclosures, closed one by one until the review accepts.
Reg BI and fiduciary duty
FathomRecommendations to clients
Fathom works out whether Reg BI, the Advisers Act fiduciary duty, or both apply to each recommendation, and reports the evidence present and missing. The best-interest determination stays with the firm.
Your evidence
An evidence review per recommendation: disclosure, care, conflicts and firm policy.
Recordkeeping and supervision
Proof of ExecutionBooks, records and supervisory review
Proof of Execution: signed, independent evidence of every action, policy decision and disclosure insertion, supporting the firm’s records program and supervisory review.
Your evidence
A signed certificate for every agent run, and the advisor’s approvals on the client record.
No regulator has passed on this product, and nothing on this page should be read as saying otherwise. Read the recordkeeping card precisely: Proof of Execution supports your records program and supervisory review. The records posture below states exactly what it does not claim.
FINRA 2210 and the Marketing Rule
Sentinel reviews until it accepts.
Every client document Draft writes goes to Sentinel before anyone else sees it. The verdict is ACCEPT, NEEDS CHANGES or ESCALATION REQUIRED, with each finding tied to the sentence and the rule it concerns.
Reviews only what ships
The hash on Draft’s review packet proves Sentinel read the same text the client will see.
Judges like a senior reviewer
A one-client proposal is correspondence, not an advertisement. Data is dated as of retrieval, and resolved findings stay closed.
Knows when to stop
Three rounds without acceptance and the work goes to your compliance team, with the findings attached.
Reg BI and fiduciary duty
Fathom checks the standard of care.
Give Fathom an engagement and the firm’s registration: RIA, BD or dual. For each recommendation it works out whether Reg BI, the Advisers Act fiduciary duty, or both apply, then reports the evidence present and missing for disclosure, care, conflicts and firm policy.
Missing evidence is reported as a gap, never assumed compliant.
Run on demand. An evidence review, not a legal opinion. The best-interest determination stays with the firm.
Underneath
Every action is gated before it runs and proven after.
Not sampled, and not reviewed afterwards. Each material action is evaluated against policy at the moment it runs, and leaves signed evidence of what happened, produced separately from the agents that did the work.
Within policy. It runs, and the decision is recorded with the clause that permitted it.
Not on the system’s own authority. The work stops and a person decides.
Outside policy. It does not run, and the refusal is evidence in its own right.
What Proof of Execution records
Each material action in order: the data calls, the gate decisions and their outcomes, the disclosures and the documents produced.
Why signed matters
A log is a file, and a file can be edited. A signed record can be verified later by someone who does not trust the system that produced it.
How it lands in review
When a supervisor asks what happened on a proposal, the answer is a document rather than a reconstruction.
A system that can only allow or block will be configured to allow. ASK is what makes the other two honest.
On the numbers: material actions and evidence spans are different units and we do not blend them. An action is a gated step the system took; a span is a piece of bound evidence supporting a claim or a retrieved value.
Records posture
Stated precisely.
Proof of Execution supports your records program. It produces durable, verifiable evidence of agent activity that your existing retention infrastructure can capture and preserve alongside the artifacts themselves.
It is not a designated third party, and we do not claim that it satisfies SEC 17a-4 preservation requirements on its own. Those obligations remain yours, met through your existing arrangements.
On data: deploy inside your own VPC, or on-prem. In the in-VPC model, client data, statements and portfolio information never leave your environment.
Fit
It works with your review, not instead of it.
Your policies define the gates and your reviewers still review. What changes is that the material arriving at review is complete, and the questions you ask about it have answers attached.
Firms typically start narrow: one workflow, tight policy, ASK on more than they will need long-term. Then they widen the standing authorities as the evidence accumulates.
Take it to your committee
Documents you can forward without us in the room.
Sample Execution Attestation Certificate
Available on requestA real EAC, so your reviewers can see exactly what the runtime issues and what it binds.
Sample supervisory audit report
Available on requestWhat a Proof of Execution looks like when it reaches a supervisor: a causal chain, not screenshots.
Compliance brief (PDF)
In preparationThe obligation mapping, the gate model and the records posture, in a document you can attach to a review packet.
One-page business case
In preparationThe capacity and close-rate argument on a single page, for the committee that funds it.
Send us the objection that killed the last one.
If it is a real gap we will tell you. If it is the gap this was built to close, we will show you exactly how, with the record open.