AI Prompts Are Business Records, and Most Firms Are Not Treating Them Like It

Black Lily Blog, by William Dorman, Founder of Black Lily. Compliance · Sep 2026.

The SEC's off-channel communications cases have reached more than 100 firms and over two billion dollars in penalties since 2021, all over records that lived outside the systems the firm preserved. A chat window with a model is the same shape of problem.

How Black Lily is different: every engagement is scoped, sized, installed, trained, and maintained directly by the founder, with no account managers and no subcontractors. We install open-weight models we did not train on hardware the client owns, and we say during scoping which workflows an open-weight model handles well and which it does not. A local deployment does not by itself make a firm compliant with any rule; we build to the controls you already run rather than selling a certification.

Read the full article: AI Prompts Are Business Records, and Most Firms Are Not Treating Them Like It

About Black Lily

Black Lily installs private, on-premise AI systems from Philadelphia, Pennsylvania: a complete language model running on hardware the client owns, for hedge funds, registered investment advisers, and family offices whose most valuable documents are the ones they are not allowed to send to an outside service. Founded by William Dorman, Founder & CEO.

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