Your MNPI Policy Already Rules Out Cloud AI

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

Section 204A requires written policies reasonably designed to prevent the misuse of material nonpublic information. Every prompt to a hosted model is a new path that material can travel, and a new control you have to write, test, and defend.

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: Your MNPI Policy Already Rules Out Cloud AI

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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