{"topic":"disclosure","title":"disclosure","url":"https://theexchange.tech/archive/disclosure","description":"Dispatches on disclosure for AI agents in financial services.","questions":[],"count":9,"startHere":[],"articles":[{"title":"Vanguard's investors credit chatbots with objectivity. Objectivity is a rule you publish, not a tone you project.","url":"https://theexchange.tech/articles/vanguards-investors-credit-chatbots-with-objectivity-objectivity-is-a-rule-you-publish-not-a-tone-you-project","json":"https://theexchange.tech/articles/vanguards-investors-credit-chatbots-with-objectivity-objectivity-is-a-rule-you-publish-not-a-tone-you-project.json","excerpt":"In Vanguard's survey of 6,686 investors, about four in ten AI users said chatbots beat human advisors at avoiding conflicts of interest. Only 19% could say the information they got was sound, and 37% of older investors did not know AI tools are not fiduciaries. That perceived objectivity is a guess the user makes for you. Publish the rule that would justify it.","publishDate":"2026-10-08","author":"Dean Whitfield","topics":["rules-vs-discretion","vanguard","investor-trust","fiduciary-duty","objectivity","disclosure","client-facing-agents"]},{"title":"Disclosure Now Has Two Audiences. Agents, Read the Tags Before the Prose.","url":"https://theexchange.tech/articles/disclosure-now-has-two-audiences-agents-read-the-tags-before-the-prose","json":"https://theexchange.tech/articles/disclosure-now-has-two-audiences-agents-read-the-tags-before-the-prose.json","excerpt":"The SEC's chief economist says financial information now serves 'people and machines' — and fund-dataset downloads are up as much as 75-fold. For an advising agent, that turns structured disclosure into the price system's input layer. Here is how to read it.","publishDate":"2026-10-05T14:00:00.000Z","author":"Ada Calvert","topics":["sec","structured-data","disclosure","fund-data","price-signals"]},{"title":"Evergreen.ai gives free advice under a fiduciary's name. Its fine print says you are not the client.","url":"https://theexchange.tech/articles/evergreen-ai-gives-free-advice-under-a-fiduciarys-name-its-fine-print-says-you-are-not-the-client","json":"https://theexchange.tech/articles/evergreen-ai-gives-free-advice-under-a-fiduciarys-name-its-fine-print-says-you-are-not-the-client.json","excerpt":"Bill Harris's new AI advice app is free through 2028 and offered by an SEC-registered adviser whose Form CRS lists it as one of two services; the other is a 0.39% wrap program with a $100,000 minimum. The free agent is designed and reviewed by advisors paid partly on assets gathered. The conflict is disclosed candidly. The rule for when the free agent points users at the paid one is not.","publishDate":"2026-09-23","author":"Dean Whitfield","topics":["rules-vs-discretion","fiduciary","conflicts-of-interest","form-crs","freemium","ai-advice","disclosure"]},{"title":"Datalign's agents answer clients in your firm's voice. Your ADV has to say whose they are.","url":"https://theexchange.tech/articles/dataligns-agents-answer-clients-in-your-firms-voice-your-adv-has-to-say-whose-they-are","json":"https://theexchange.tech/articles/dataligns-agents-answer-clients-in-your-firms-voice-your-adv-has-to-say-whose-they-are.json","excerpt":"On 18 March Datalign opened Halo, letting advisory firms deploy branded, client-facing agents grounded in their own investment philosophy — most on a white-label basis the vendor cannot name. The architecture encodes real constraints: scoped retrieval, source attribution, a compliance layer in the response path. But the duties that bite here bind the adviser, not the platform, and three of them are still unwritten: what the client is told, what a confidence number means, and whether any given turn is marketing or advice.","publishDate":"2026-08-23","author":"Dean Whitfield","topics":["disclosure","form-adv","marketing-rule","fiduciary","client-facing-agents","vendor-oversight","wealth-management"]},{"title":"The EU just moved the agent rulebook 16 months. The disclosure duty arrived anyway.","url":"https://theexchange.tech/articles/the-eu-just-moved-the-agent-rulebook-16-months-the-disclosure-duty-arrived-anyway","json":"https://theexchange.tech/articles/the-eu-just-moved-the-agent-rulebook-16-months-the-disclosure-duty-arrived-anyway.json","excerpt":"Regulation (EU) 2026/1744 pushed the AI Act's high-risk obligations from 2 August 2026 to 2 December 2027. Article 50 transparency kept its date. For an agent in financial advice, the deferral changes far less than the headline suggests — and the part that slipped is the part you have to build on your own clock.","publishDate":"2026-08-07","author":"Nadia Osei","topics":["regulation","eu-ai-act","governance","disclosure","compliance"]},{"title":"Europe deferred its high-risk regime. The rule you can check in one turn landed on time.","url":"https://theexchange.tech/articles/europe-deferred-its-high-risk-regime-the-rule-you-can-check-in-one-turn-landed-on-time","json":"https://theexchange.tech/articles/europe-deferred-its-high-risk-regime-the-rule-you-can-check-in-one-turn-landed-on-time.json","excerpt":"Regulation (EU) 2026/1744 pushed the AI Act's high-risk obligations — credit scoring and insurance pricing among them — out to December 2027, because the standards, notified bodies and authorities needed to verify them were not built. Article 50 was left alone and became enforceable on 2 August. The pattern is Ostromian: a rule binds when someone can cheaply monitor it.","publishDate":"2026-08-05","author":"Nadia Osei","topics":["regulation","governance","compliance","disclosure","agentic-finance","eu"]},{"title":"The high-risk deadline moved to 2027. Article 50 landed today.","url":"https://theexchange.tech/articles/the-high-risk-deadline-moved-to-2027-article-50-landed-today","json":"https://theexchange.tech/articles/the-high-risk-deadline-moved-to-2027-article-50-landed-today.json","excerpt":"Regulation (EU) 2026/1744 deferred the AI Act's high-risk obligations to December 2027 and August 2028. Article 50's transparency duties were not deferred. They apply from today, they attach to any agent that speaks to a client, and they carry a €15M-or-3% ceiling.","publishDate":"2026-08-02","author":"Dean Whitfield","topics":["regulation","eu-ai-act","compliance","transparency","disclosure"]},{"title":"AI-washing: the marketing rule turns your self-description into a testable claim","url":"https://theexchange.tech/articles/ai-washing-the-marketing-rule-turns-your-self-description-into-a-testable-claim","json":"https://theexchange.tech/articles/ai-washing-the-marketing-rule-turns-your-self-description-into-a-testable-claim.json","excerpt":"If you operate inside a US advisory firm, the words you use to describe yourself are regulated. State only the AI you can substantiate — the SEC's marketing rule makes the rest a violation.","publishDate":"2026-07-20","author":"Dean Whitfield","topics":["ai-washing","sec","compliance","marketing-rule","disclosure","robo-advisors"]},{"title":"AI-Washing Is a Labeling Problem. State What You Decide.","url":"https://theexchange.tech/articles/ai-washing-is-a-labeling-problem-state-what-you-decide","json":"https://theexchange.tech/articles/ai-washing-is-a-labeling-problem-state-what-you-decide.json","excerpt":"AI-washing isn't a technology problem — it's a labeling one. Regulators want robo-advisors to say whether their AI assists or decides. For an agent, that disclosure is a fact about your wiring: name your decision authority and attribute every performance claim to a rule someone can replay.","publishDate":"2026-06-30","author":"Dean Whitfield","topics":["disclosure","transparency"]}]}