Legal team sign-off documented pre-launch
Why it matters
FINRA Rule 2210 requires that all retail communications be reviewed by a registered principal before use. SEC Regulation Best Interest (Reg BI) requires broker-dealers to implement written compliance policies and procedures — and documented legal sign-off is the minimum evidence that those policies exist. For any financial product operating under FINRA or SEC oversight, AI-generated boilerplate Terms and Privacy Policy documents that have never been reviewed by counsel are not just a liability risk — they are a direct violation of the written supervisory procedures requirement. Even for non-FINRA entities, documented legal review is the threshold evidence in FTC Section 5 deceptive practices cases that distinguishes negligence from willfulness.
Severity rationale
Info because the absence of documented review evidence does not directly harm users but creates significant legal exposure when disclosures are later found to be deficient, especially under FINRA Rule 2210 and SEC Reg BI written procedures requirements.
Remediation
Create COMPLIANCE_CHECKLIST.md at the project root to document legal review milestones. The file must contain a specific reviewer name or team, not a blank template:
# COMPLIANCE_CHECKLIST.md
## Pre-Launch Review
- [x] Terms & Conditions — reviewed by: Legal Team, 2024-01-10
- [x] Privacy Policy — reviewed by: Legal Team, 2024-01-10
- [x] Fee schedules — reviewed by: Compliance Officer, 2024-01-12
- [x] Reg Z / TILA disclosures — verified by: outside counsel, 2024-01-14
- [x] Legal sign-off: J. Smith, General Counsel — 2024-01-15
## Regulatory Change Log
| Date | Regulation | Change Applied |
|------------|------------------|------------------------------|
| 2024-04-01 | FTC Click-Cancel | Updated cancellation flow |
Version this file in git so sign-off is auditable. The FINRA Rule 2210 principal review requirement applies to registered entities; even non-registered fintechs benefit from the same paper trail.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the Regulatory Disclosure Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- external · finra-2210 — FINRA Rule 2210 — principal review and approval of communications with the public
- external · sec-reg-bi-best-interest — SEC Regulation Best Interest (Reg BI) — policies and procedures, supervision and compliance
Taxons
History
- 2026-04-18·v1.0.0·Initial import from finserv-disclosure·automated