How we handle your clients’ data

What we take, where it goes, and who sees it.

For compliance, operations and principals

Lead reactivation works the prospects your firm has already generated — people who asked about your services, were followed up once or twice, and then were not. We rank them by likelihood to book a conversation and work the list from the top, so your advisors spend their time on the people most likely to sit down with them.

Every one of those records is regulated: by Regulation S-P, by your supervisory and recordkeeping rules, and by federal and state telemarketing law. This document sets out, control by control, how the engagement keeps your firm inside those rules — and which decisions stay with your firm. It is written to be read by your Chief Compliance Officer and filed with your vendor due diligence.

Sections 02 to 06 are the plain-English part. They show the whole system in pictures, explain the four things the ranking looks at, and follow one example lead from your CRM to your advisor’s desk. The sections after them are the detail your compliance team will check.

01

Commitments

Ten commitments, before the detail

• 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails, addresses and account numbers stay in a secure environment. The AI provider sees a random ID and a few short facts, nothing more.
• 02 · Nothing goes out without your approval — Your principal or CCO approves every template before use. Our review sits on top of yours, never in place of it.
• 03 · Every message lands in your archive — Outreach goes through your archived channels, or is captured into your archive as it is sent. Nothing off-channel.
• 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending. Opt-outs are permanent.
• 05 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment without your written instruction.
• 06 · Breach notice within 72 hours — As soon as possible and no later than 72 hours — the window Regulation S-P requires your firm to put in our contract.
• 07 · Return and destruction, certified — At the end of the engagement your data, including the identity key, is returned or destroyed, and we confirm it in writing.
• 08 · No investment advice — Messages invite a conversation with your advisor. No recommendations, performance figures, projections or testimonials.
• 09 · A fee structure your compliance team chooses — A flat fee or a results-based fee, with how each is treated under your rules set out in section 14.
• 10 · Evidence on request — Every control here has something you can inspect. We complete your due diligence questionnaire during onboarding.

02

The whole picture

The system on one page

The system works in three zones. Names and contact details stay on your side. Our scoring works only with a random ID and a few short facts. The results come back to your side, where your firm approves and sends.

G1 — the agreement and intake review — clears before any data moves. G7 covers retention and destruction.

Dashed gold-edged boxes, marked G1 to G7, are compliance gates. Nothing passes a gate until it clears. Section 03 lists what each one checks.

03

Step by step

From our first conversation to the first message

Seventeen steps in five phases. The gate marks show where a compliance check has to clear before the work moves on.

Onboard (before any data)

• 01 First conversation — How your firm works with prospects today
• 02 Agreement — Roles, purpose, subprocessors, 72-hour notice G1
• 03 Intake review — Lead sources, consent wording, opt-outs G1
• 04 Secure environment — In your environment, or our workstation

Prepare (on your side)

• 05 Map your stages — Your CRM statuses to eight shared stages
• 06 Check the list — Opt-outs, Do Not Call, clients, complaints G2
• 07 Swap names for IDs — A random ID; the key stays with you
• 08 Notes into facts — Fixed-list answers; figures become tiers G3

Rank (Tez scoring)

• 09 Score — Intent, Opening, Reachability, Fit
• 10 Tier and reasons — A to D, with the top reasons
• 11 Short summary — Why call, and an opening line, checked G4
• 12 Next step — Channel by consent, and timing

Act (on your side)

• 13 Match back — The ranked list appears in your CRM
• 14 Your approval — Principal or CCO approves the wording G5
• 15 Send — Re-checked at sending; through your archive G6

Learn (ongoing)

• 16 Record outcomes — Booked, held, signed; a held-back group
• 17 Improve and report — Your ranking only; results you can check G7

04

The ranking

How the list is put in order

Every lead is checked first, then looked at through four factors. The factors combine into one score, and the list is sorted by it. The sorting is plain arithmetic, not an AI model, so every score can be explained in a sentence.

How the ranking gets better

• 01It starts from your team’s experience — Your advisors tell us how often each kind of paused prospect comes back. Those estimates set the first odds. Until your results come in, the scores are educated estimates, and we say so.
• 02It corrects itself from your results — As meetings are booked, held or declined, the odds for each reason move toward what actually happened at your firm.
• 03It becomes a model of your firm alone — After about 300 recorded outcomes, the ranking is fitted to your firm’s results. It is never trained on, or pooled with, another firm’s data.
• 04A held-back group keeps us honest — With your agreement, about one lead in ten is held back and not contacted for a set period. Comparing the two groups shows what the outreach actually changed, rather than what would have happened anyway.

05

A worked example

One lead, from your CRM to your advisor

Karen Mills is fictional. Her record is shaped like a real one. Follow it through the four cards, left to right and top to bottom.

1 · Your CRM record (stays with you)

2 · What we receive (leaves your side)

Never leaves your side: her name, phone, email, CRM ID, the note itself, the asset figure, exact dates.

3 · What comes back (back to you)

4 · In your CRM (stays with you)

No text consent on file, so the next step is email. Her inquiry is over three months old, so a Do Not Call check comes before any call. Her advisor sees her name here, in your own CRM, for the first time.

• 01Her note became a few facts — “401(k) rollover” left only as “waiting on an event.” If your CCO approves a short list of event types, the summary can be more specific without the note ever leaving.

06

The suggestion

How the “why call” note is written and checked

Each lead comes back with a reason line in fixed wording and a short summary drafted by an AI model, both written only from the facts in card 2 of section 05. The AI writes; it does not decide. The order comes from arithmetic, and your firm approves anything sent.

The four checks at gate G4

• No personal data — The draft may not contain a name, number, email or address. Names appear only as a placeholder, filled in on your side at sending.
• No advice, no promises — No recommendations, performance figures, projections, rates or guarantees. The draft invites a conversation with your advisor, nothing more.
• Nothing made up — Every statement in the summary must trace back to one of the facts it was given. A statement that does not is treated as a failure.
• Your never-say list — Phrases and topics your firm rules out are blocked, on top of the general rules above.

07

Roles

Your firm stays the covered institution

Under Regulation S-P your firm is the covered institution and Tez I Solutions is a service provider. You share consumer information with us under the service-provider exception (17 CFR 248.13), on a contract that limits our use of it to this engagement; the reuse and redisclosure limits in 248.11 then bind us. Prospects who asked about your services but never opened an account are consumers under the rule, so the dormant list is covered in full. Since the 2024 amendments, your incident response program must include written oversight of service providers. This is how responsibility divides.

08

Data

What we take, and what we never take

The least data that lets the list be ranked and worked. Where a figure carries signal, we keep a tier and drop the figure.

09

The privacy layer

Where AI sits, and what it sees

Notes are the most sensitive part of a record and the most useful. So they are read where they already are, and only short answers leave. Five layers make sure of it.

10

Where it runs

Two ways to run the secure environment

The secure environment is where identifiable data lives during the engagement, and your firm chooses where it sits. In both options the key table never leaves it, and the AI provider receives only a random ID and fixed-list facts.

Workstation standard, when Tez operates it

• Encrypted at rest — Full-disk encryption, plus a separate encrypted volume for each firm’s data.
• Dedicated and locked down — An OS account used only for client data, multi-factor sign-in, screen lock, current patches, endpoint protection.
• No cloud sync — Client data is never stored in a synced folder or consumer cloud backup, and is excluded from sync by configuration.
• Wiped at the end — The firm’s volume is destroyed at termination and the destruction certified in writing.

11

Security and incidents

The controls, and what happens if one fails

If something goes wrong

• 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
• 02 · Notify you within 72 hours at the latest — Which records and fields, what window, what we have done. Updates follow as we investigate.
• 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation.
• 04 · Support your notice, never pre-empt it — Customer notice is your firm’s decision, within 30 days under Regulation S-P. We never contact your customers about it.

12

Supervision and records

Your supervisory system covers this work

Outsourcing does not outsource responsibility (FINRA Notice 21-29), and an AI-drafted message is still your firm’s communication (Notice 24-09). With the SEC’s AI proposal withdrawn as of June 17, 2025, these existing rules are the standard.

• 01Broker-dealers — FINRA Rule 2210 — A template used with more than 25 retail investors in 30 days is a retail communication, approved by your registered principal before use. Individual replies are correspondence, reviewed under your Rule 3110(b) procedures.
• 02Investment advisers — the Marketing Rule — Outreach offering your services may be an advertisement under Rule 206(4)-1; your CCO classifies and approves each template before use.
• 03Content limits — No performance figures, projections, testimonials, guarantees or product recommendations — only a fair, balanced invitation to talk to an advisor.
• 04Every message is a firm record — Exchange Act Rule 17a-4 and FINRA Rule 4511; Advisers Act Rule 204-2. Every message, outbound and inbound, goes through or is captured into the archive you already use.
• 05An approval trail you can produce — For every template: the AI draft, the approved wording, who approved it and when.
• 06Rails the drafting stops at — Identity, account specifics, complaints and anything that reads as advice go to your advisor. Outreach never asks a lead to confirm personal or account details (Regulation S-ID). Every AI draft passes gate G4 before your principal sees it (section 06).

13

Consent

No evidenced consent, no text message

Under the Telephone Consumer Protection Act the party that sends a message can be liable for it directly. So consent is enforced in software at the moment of sending, not left to policy.

• 01 · A consent history, not a checkbox — Each lead’s consent is an append-only record of source, wording, channel and date. Contactability is derived from it, never overwritten.
• 02 · Checked when the message sends — Consent, suppression, Do Not Call and quiet hours are rechecked at sending, not at list-building. Yesterday’s opt-out holds today.
• 03 · Aged leads without evidenced consent — Email, or your advisors directly — not text. An inquiry over three months old is no established business relationship for Do Not Call.
• 04 · Do Not Call and reassigned numbers — Checked against the National Do Not Call Registry and the FCC Reassigned Numbers Database. Results dated and stored.
• 05 · Quiet hours and state law — 8am to 9pm in the lead’s local time, narrower where required. Florida, Oklahoma, Maryland, Washington and Texas SB 140 rules applied by state.
• 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your advisor is honoured on every channel and survives any re-import. Email unsubscribes within 10 business days.

14

How we are paid

Two fee models, and how each is treated

We offer two models. Fees are set in conversation and are not in this document. What belongs here is how each model is treated under the rules that apply to your firm, so your compliance team can choose with that in view.

Model A: Flat monthly fee

A fixed fee for operating the service. It does not depend on accounts opened, assets brought in or transactions.

• Broker-dealers. The payment is not transaction-based, which supports your firm’s determination under FINRA Rule 2040.
• Investment advisers. We operate your outreach rather than endorse your firm, and the fee is not paid per client referred.
• The simplest model to approve, document and supervise.

Model B: Results-based fee

A share of revenue attributed to reactivated leads, measured from your CRM’s own records.

• Broker-dealers. A fee that depends on accounts or transactions is transaction-based. FINRA Rule 2040 and Exchange Act section 15(a) bar paying it to an unregistered person whose activity requires registration. Tez I Solutions is not a registered broker-dealer.
• Investment advisers. A fee per new client or a revenue share is likely a compensated promoter arrangement under Rule 206(4)-1: written agreement, disclosure and oversight, and state solicitor rules may apply.
• Offered only where your compliance team and counsel approve the structure in writing.

15

Subprocessors and contract

Who else touches the data, and what we sign

The full list is an exhibit to your agreement. We give 30 days’ notice before adding or changing a subprocessor.

What the agreement contains

• Roles and purpose — Your firm as covered institution, Tez as service provider; use limited to this engagement, as Regulation S-P 248.13 requires.
• No secondary use — No training, no sale, no reuse across clients, no enrichment without written instruction.
• Security exhibit and 72-hour notice — The controls in sections 09 to 11, as binding terms.
• Consent warranty — Your firm’s representation of how the leads were obtained.
• Privacy requests — Access, correction and deletion within your deadlines, including state privacy laws for data outside the GLBA exemption.
• Audit, return and destruction — Reasonable audit and questionnaire rights; return or certified destruction at termination.

16

Regulatory map

Each rule, and where it is addressed

17

References

Every requirement, traced to its source

Each commitment in this document rests on a primary source: a statute, a regulation, a rule, a regulator’s own guidance, or a court decision. They are listed here so your compliance team can check our reading against the text. Links were current in October 2026.

18

Limits

What this document is not

• 01Not legal advice — Your Chief Compliance Officer and counsel decide how these rules apply to your firm. This document tells them what we do so they can.
• 02Not a SOC 2 report — We do not hold a SOC 2 attestation. We complete your due diligence questionnaire and provide the policies and evidence behind each control instead.
• 03Not a registered firm — Tez I Solutions is not a broker-dealer or investment adviser, does not give investment advice, and does not solicit securities transactions.
• 04Not permanent — Current as of October 2026. Rules in this area are moving — the FCC’s consent revocation rules among them. We review this document at least once a year and whenever a rule it relies on changes.
• 05Not a promise of results — A score says which prospects to contact first, not who will book. Until your firm’s own outcomes are recorded, the odds behind it are estimates drawn from your team’s experience.

A1

Commitments

Ten commitments, before the detail

• 01 · Your accounts, on business terms — We work only in accounts your business owns, on business plans. Never in a personal or consumer account — ours, yours or an employee's.
• 02 · A named user, never a shared password — You add us as a named user with our own sign-in and multi-factor authentication. We never ask for a shared password, and you should never send one to us by email.
• 03 · The least access that does the job — Each connection reaches only the data its workflow needs. Admin rights are used for set-up tasks, logged, and reduced afterwards.
• 04 · Nothing goes live without your approval — Every connection, workflow and set of instructions is approved by you, in writing, before it is switched on. So is every change to one that is already running.
• 05 · Automated where it is routine, a person in the loop where it is not — Routine, rule-based work can run on its own once you have approved it: sorting and tagging, summaries for your team, filing, and fixed-wording notices such as an appointment reminder from a template you signed off. Anything that needs a decision or a judgement — a reply written for a particular customer, a price, a term, a commitment, or anything your industry's page marks for review — has a person on your side in the loop before it goes anywhere. Each workflow's data sheet (A3) states which kind it is. Where your industry's page requires a person to review every customer message, that rule applies instead.
• 06 · Your data stays in your tools — We build and test inside your workspace. We do not copy your business data into Tez's own AI accounts. Where we need examples outside your tools, we use made-up records.
• 07 · Your data serves your business only — No reuse across clients, no sale, no training of anything by us. Prompts, instructions and workflows built from your material are yours and are not reused for anyone else.
• 08 · Vendor data settings confirmed in writing — During onboarding we read each tool's current data terms, set its controls with you, and give you a written record. We re-check it whenever a vendor changes its terms.
• 09 · Incident notice within 72 hours — As soon as possible and no later than 72 hours, or sooner where your industry's page says so.
• 10 · Access removed, everything handed over — At the end, our access is removed, every credential we created is revoked or rotated, and every workflow is documented and handed over. We confirm it in writing within 30 days.

Evidence on request: every control in this document has a record you can inspect, listed in section A5. If you send us a security questionnaire, we complete it during onboarding.

A2

Accounts and access

Whose accounts, and how we get in

The AI tools, the systems they connect to and the accounts that run them all belong to your business. We are given access to them; we never hold them. That is what makes the work portable: if we part ways, everything keeps running and nothing has to be moved out of our name.

Nothing in this section starts before you have decided to work with us. The first session is a conversation. We do not ask for logins, exports or files beforehand.

Who owns what

How access is set up

• 01 · You decide what we need — We list the systems and the role each one needs, and why. You agree or strike items out.
• 02 · You add us — Usually by adding us as a user, on a call where we walk through it together. A password is never sent.
• 03 · We confirm the safeguards — Multi-factor authentication on, role as agreed, sign-in recorded in the access record.
• 04 · Reviewed every quarter — We go through the access record with you and remove anything no longer needed.
• 05 · Removed at the end — Section A5 sets out how access ends.

Roles

Where a state privacy law reaches your business, we act as your service provider or processor for the access we hold, and the agreement says so.

A3

What the tools can see

Connections, scopes, and what stays out

An AI tool connected to one of your systems can see whatever that connection lets it see. An assistant that searches your files can surface anything the person using it is allowed to open — Microsoft says of its own Copilot that it "only surfaces organizational data to which individual users have at least view permissions." So the work starts with permissions, not prompts.

Before anything is connected

• Who can see what — Before an assistant is pointed at a shared drive, inbox or CRM, we review who can open what. Folders that are open to everyone but should not be are fixed first, with your approval.
• One data sheet per workflow — Every workflow gets a written sheet: what it reads, what it writes, who sees the result, and where a person reviews it. You approve the sheet before we build.
• Add-ons are vendors too — A plug-in, connector, custom GPT or agent from a third party is another company handling your data. None is installed without your approval and a record of its data terms.

What a data sheet looks like

Illustration — not real client data.

What stays out by default

Unless your written decision says otherwise, after we have shown you what the vendor's terms and your industry's rules say, these are kept out of every prompt, instruction file and connection:

• Social Security numbers, tax IDs, driver's licence and other government ID numbers
• Full bank account and card numbers
• Passwords, access codes, gate, door and alarm codes
• Health information
• Anything your industry's page (A7) marks as restricted

Where a connection would expose one of these — a folder of scanned IDs, a CRM field holding card numbers — the connection is narrowed to leave it out, or not built.

Before a workflow goes live

AI tools make mistakes. Every workflow is built on the assumption that a draft can be wrong, which is why the review step is part of the design rather than a suggestion.

A4

Model providers and training

What the vendors do with your data, and how we check

When your team or a workflow uses ChatGPT, Claude, Copilot or Gemini, the vendor processes that data under its contract with your business. Tez is not a reseller or partner of any AI vendor, and not a party to those contracts. Whether a vendor trains its models on your data, how long it keeps prompts, whether its staff can review them, and where it processes them are set by the vendor's terms and by the plan you are on. Those terms change. So we do not promise what a vendor will do. We promise what we will do.

What we do

• 01 · List every tool — Each AI tool and AI feature you pay for, the plan it is on, and who holds a seat.
• 02 · Read the current terms — For each one we record what the vendor says about training on your data, retention, human review, where data is processed, and which admin controls exist. Each entry carries the date and the address of the page we read.
• 03 · Set the controls with you — Where a tool offers a choice — training opt-outs, retention periods, chat history, which add-ons are allowed — we recommend the most protective setting that still does what you need, and you decide.
• 04 · Give you the record — The settings record is yours, in writing. Your compliance contact can file it with your vendor reviews.
• 05 · Re-check when terms change — When a vendor changes its data terms, we re-read them, update the record and tell you if anything moved. We also re-check the whole record at least every six months.

What the main vendors said when we checked

Read on each vendor's own page on 6 October 2026. This is the vendor's statement to its customers, not a commitment by Tez. If it changes, the vendor's current terms govern, and we update your record.

Consumer plans and personal accounts

Consumer plans run on different terms from business plans — Anthropic's Commercial Terms, for one, state that they do not cover its consumer offerings. We do not do business work in consumer or personal accounts, and we do not rely on a consumer plan's settings to protect business data.

Our own tools

We use AI tools of our own to write code and documentation. Your business data does not go into them. Anything we build for you is built and tested in your workspace, or against made-up records.

A5

Records, security and incidents

What we keep, how it is protected, and what happens if something fails

Records you can inspect

Records describe what we built and changed. They live in a location your business owns, and they do not contain your customers' data.

Changes to something already running

Every change to a live workflow is described, approved by you, tested, logged and reversible — the previous version is kept. If a vendor update breaks a workflow, or a workflow starts doing something it should not, we may pause it at once to stop harm, and tell you the same day. We do not change what a workflow does without your approval.

Security controls

If something goes wrong

An incident includes a workflow sending or showing data to the wrong person, a connection reaching more than its sheet allows, a suspected compromise of a Tez sign-in, and a vendor incident we learn of that affects your workspace.

• 01 · Contain — Pause the workflow, revoke the affected credential or connection, and stop the exposure.
• 02 · Notify you within 72 hours at the latest — Which systems and data, what window, what we have done. Sooner where your industry's page sets a shorter time. Updates follow as we investigate.
• 03 · Preserve evidence — Logs, the change log and the vendor's audit records are kept intact for your investigation.
• 04 · Support your notice, never pre-empt it — Whether customers or regulators are told is your decision. We never contact your customers about it. A vendor's own incident notice comes to you under your contract with that vendor.

When the engagement ends

Everything we build is yours — documented and portable. If we part ways, it keeps working and your team knows how it runs.

A6

Limits

What this document is not

• 01 · Not legal advice — Your counsel or compliance officer decides how your industry's rules apply to your business. This document tells them what we do so they can.
• 02 · Not a SOC 2 report — We do not hold a SOC 2 attestation. If you send a security questionnaire, we complete it and provide the policies and evidence behind each control instead.
• 03 · Not the vendor — We do not run the AI vendors' systems or set their terms. Their security, retention, outages and incidents are governed by your contract with them. We are not a reseller, partner or certified provider of any AI vendor.
• 04 · Your obligations stay yours — Using AI tools does not move your duties to us: licensing, supervision, record keeping, privacy notices and your staff's use of AI remain your business's responsibility. We build to them, as your industry's page sets out.
• 05 · Not a promise about AI output — AI tools can be wrong, and confidently so. That is why anything that needs a judgement has a person in the loop, and why no workflow makes a decision your business would otherwise make.
• 06 · Not permanent — Current as of October 2026. Vendor terms and the rules on AI change often. We review this document at least once a year, and whenever a vendor term or rule it relies on changes.

A7

Financial advisory

What your industry's rules mean for your AI tools

No rule written for AI binds a broker-dealer or investment adviser today. The SEC withdrew its AI proposal in June 2025 [8], and FINRA has said its existing rules apply whether a firm builds an AI tool or uses a vendor's [5]. That makes the familiar rules the standard: Regulation S-P for customer information, supervision and approval for communications, and books and records for everything sent. Each one reaches AI tools directly. These are the rules, and what we do about each.

In practice

• A workflow may draft a meeting follow-up for an advisor to edit and send through your archived email. It does not send on its own, and it never includes performance figures or a recommendation.
• An assistant may answer staff questions from your written policies and procedures. It is not given access to custodian data or account statements unless your CCO approves that scope in writing.
• An AI notetaker is switched on only for meetings your firm has decided to record, and its notes are kept where your archive can preserve them.
• During onboarding we check for AI tools staff are using on client data without approval, and list them for your CCO.

A8

Sources

Where these rules come from

1. Regulation S-P and Regulation S-ID, 17 CFR Part 248 — https://www.ecfr.gov/current/title-17/chapter-II/part-248 2. SEC Release 34-100155, Regulation S-P amendments, May 2024 — https://www.sec.gov/files/rules/final/2024/34-100155.pdf · SEC, Regulation S-P Small Entity Compliance Guide — https://www.sec.gov/files/rules/final/2024/regulation-s-p-small-entity-compliance-guide.pdf 3. FINRA Rule 2210, Communications with the Public — https://www.finra.org/rules-guidance/rulebooks/finra-rules/2210 4. FINRA Rule 3110, Supervision — https://www.finra.org/rules-guidance/rulebooks/finra-rules/3110 5. FINRA Regulatory Notice 24-09, Generative AI — https://www.finra.org/rules-guidance/notices/24-09 6. Advisers Act Rule 206(4)-1; SEC Release IA-5653 — https://www.sec.gov/files/rules/final/2020/ia-5653.pdf 7. FINRA Rule 4511 and Exchange Act Rule 17a-4 — https://www.finra.org/rules-guidance/rulebooks/finra-rules/4511 8. SEC withdrawal of proposed rules, effective June 17, 2025 — https://www.sec.gov/rules-regulations/2025/06/s7-12-23 9. FINRA Regulatory Notice 21-29, Vendor Management and Outsourcing — https://www.finra.org/rules-guidance/notices/21-29

• 01FINRA, 2026 Annual Regulatory Oversight Report — https://www.finra.org/sites/default/files/2025-12/2026-annual-regulatory-oversight-report.pdf · SEC Division of Examinations, Fiscal Year 2026 Examination Priorities — https://www.sec.gov/files/2026-exam-priorities.pdf
• 02Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809 — https://www.law.cornell.edu/uscode/text/15/chapter-94