No rule requires financial advisors to tell clients they use AI. The SEC has no disclosure mandate for RIAs on this, FINRA has none for broker-dealers, and no regulator has published a form that asks you to reveal which tools helped draft your newsletter.
But the rules are only half the conversation. The other half is trust, and that's the half your clients actually feel.
An advisor I work with through Amplify for Advisors told me about a review meeting earlier this year. His client, a retired engineer, asked him directly whether he was using ChatGPT to write his monthly newsletter. He paused, then told the truth. He drafts with AI, he edits everything himself, and nothing reaches clients without his review.
The client smiled and said he'd hoped so. He'd been using AI to plan woodworking projects in his garage and figured his advisor should be at least as current as he was.
The honest answer made the relationship stronger. Here's why this matters for how you handle the same question.
Is There a Rule That Requires Advisors to Disclose AI Use?
Not right now. For RIAs, the SEC regulates AI use through the same framework it applies to everything else, meaning fiduciary duty and the prohibition on misleading statements. Neither one includes a standalone requirement to announce that AI helps with your writing, your meeting prep, or your research.
For broker-dealers, FINRA applies its existing communications and supervision rules to AI-assisted work. Those rules care whether the content is fair and accurate, and they don't ask how it was produced.
There's one place where disclosure can become mandatory. If AI plays a material role in how you actually manage money or generate recommendations, that belongs in your Form ADV like any other material fact about your process. Using AI to draft a client letter doesn't rise to that level, and an algorithm picking your trades very well might.
What Do Regulators Actually Care About?
Regulators care when what you say about AI doesn't match what you actually do. In March 2024, the SEC brought its first AI washing cases against two investment advisers, Delphia and Global Predictions, for claiming AI capabilities they didn't have. The two firms paid $400,000 in combined penalties.
Notice what's missing from the enforcement record. Nobody has been fined for using AI and describing it honestly. The cases punish firms for overstating it.
That pattern helps explain why AI has become the loudest topic in compliance. The 2026 Investment Management Compliance Testing Survey, released in late July by the Investment Adviser Association, ACA Group, and Yuter Compliance Consulting, found that 85% of the 411 participating firms named AI their top compliance concern, which the sponsors called the most dominant single response in the survey's 21-year history.
And examiners are asking about it in regular exams now. If you want to see the specific documents SEC examiners request when AI comes up, I walked through them in What Do SEC Examiners Ask Financial Advisors About AI?
What Do Clients Actually Think About Advisors Using AI?
They're already using it themselves, and some of them are checking your work with it. In research Edward Jones released this summer, built on a Morning Consult survey of 201 financial advisors conducted in May 2026, 38% of advisors said clients now compare their recommendations against what online and AI sources say.
The same research found that 82% of advisors already use AI tools in their practice, while 68% believe keeping client trust depends on human interaction. Both of those numbers can be true at once. The tools are everywhere, and the relationship still runs on people.
Here's what that means practically. When a client asks whether you use AI, they've usually already formed an opinion about the technology from their own life. The question is usually curiosity, and sometimes it's hope that you're keeping up.
I teach financial advisors how to use AI for content, communication, and client attraction. New frameworks and prompts every Tuesday and Friday. Subscribe free or get full access for $20/month at amplifyforadvisors.substack.com.
How Should You Answer When a Client Asks If You Use AI?
Answer it the way you'd want your own advisor to. A good answer covers what you use AI for, what stays human, and how client information is protected.
The first part is easy. You might say AI helps you draft letters, prepare for meetings, and research faster, which gives you more time for the work your families actually hired you for. I've written before about how advisors use AI for client communication beyond content creation, and every use in that article fits comfortably in this sentence to a client. And if a few of those uses aren't part of your practice yet, the AI Setup Sprint gets the tools in place so you can give that answer from experience.
The second part is where trust gets built. Every recommendation, every judgment call, and every final word comes from you. AI drafts and you decide, and your clients should hear that in exactly those terms.
The third part matters more than many advisors realize. Client personal information never goes into public AI tools, and you should be able to say so plainly because it's true. If that part of your setup isn't settled yet, I wrote about exactly where the line sits in PII, NPI, and AI for financial advisors.
One more piece makes this whole answer easier to give. When AI drafts in your actual voice, the review step stops being a rewrite, and the "I edit everything myself" line stays true without eating your week. If you want to go deeper on that, the Voice Guide Launch Pad takes you from writing samples to a complete AI voice guide in one weekend.
Should AI Disclosure Go in Your Written Policy?
I think it's smart, even though nothing forces you to put it there. Your AI use policy already covers which tools are approved, what data can touch them, and how outputs get reviewed. Adding a short section on how you'll talk with clients about AI turns an awkward future moment into a settled one.
Firms are moving in this direction fast. In that same 2026 compliance survey, 86% of firms reported having acceptable use policies for AI, up from roughly 64% the previous fall. The good news is that a solo advisor can get there in an afternoon, and the policy that matches what you actually do beats the impressive one that doesn't.
If you don't have a written policy yet, start smaller than you think. I covered whether you need one at all in Can Financial Advisors Use ChatGPT? And if you want the finished version instead of a blank page, the Compliance-Safe AI Playbook includes a sample AI use policy you can adapt to your firm, plus the language swap tables and pre-publish checklist that keep the rest of your AI work on solid ground.
The Bottom Line for Advisors Talking About AI
No rule requires you to disclose that AI helps you write, prep, and research, and no rule rewards you for hiding it either. The regulatory risk lives almost entirely in overstating what your AI does, and the relationship risk lives in a client sensing you dodged a direct question.
So decide your answer before anyone asks. Say what AI does for your practice, say what stays yours, and mean both.
Chances are, the client asking has been hoping you'd say exactly that.
Sam Farrington, CFP®
Sam Farrington is a Certified Financial Planner and the creator of Amplify for Advisors. He teaches financial advisors how to use AI to communicate authentically, stay compliant, and build a practice that attracts the right clients. He publishes twice weekly on Substack and is building the first suite of AI Skills designed specifically for financial advisors.
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