The IDR Principles · Edition 1.0

If Done Right

The AI Governance Framework for Regulated Financial Firms.

Twelve principles for governing AI at an SEC-registered investment adviser. Written from inside a practicing firm, tested in production, and built around the questions an examiner will actually ask.

By Brandon Veldman, CFA and Stefan Whitwell, CFA, CIPM

Foundation
Principles 1 to 3
Intelligence
Principles 4 to 7
Operations
Principles 8 to 10
Evolution
Principles 11 to 12

The human reality of this moment

Two desks. The same problem, the same side.

Inside one firm, two people carry the same problem from different chairs. The chief compliance officer already knows AI is in the workflow and cannot fully prove how it got there. The owner controls the budget, the authority, and the attention that would fix it, and does not yet know the clock is running. They are not adversaries. They are the two people who, together, decide whether the firm walks into its next examination with a story or with a silence.

The compliance officer’s desk

The firm’s compliance officer has an AI Use Policy somewhere: two pages he started last year and never finished. It sits on a running list of thirty-one items, beneath a line at the top that just says “think.” He does not have time to think about the thing he is most worried about. He has time to react to it, and that is where governance quietly breaks down.

The owner’s desk

The founder who owns most of the firm is building the version that lasts twenty years, with successors he trusts. He has read the words “compliance program” twice this week. What he does not have is the time or the background to see that his people are weaving AI into their work one phone at a time. It is not on his list because he doesn’t know it needs to be.

Going wide: the explosion

Most firms have never counted how many doors AI has already opened inside them.

195
AI touchpoints mapped to existing SEC priorities
more than 15,000
SEC-registered investment advisers nationwide
roughly 500
examiners covering all of them
more than 3,000
screening iterations behind the framework

Every AI touchpoint maps to at least one existing SEC priority, and most map to several. The regulatory architecture built over the last eighty-six years already reaches every one of them. The rules did not wait for a new one to be written. Neither should your governance.

The framework

Twelve principles. Four categories. One defensible architecture.

The IDR Principles define what defensible AI means for a regulated firm. Each one is operationally testable, maps to a specific examiner question, and produces a specific piece of evidence. If a principle produces no artifact, it is not yet operational.

Foundation

Principles 1 to 3

The structural baseline: a documented chain of origin, written governance that exists before the exam letter arrives, and every workflow built for the show me moment. Three prerequisites. Skip one and the others collapse.

  • 1.Chain of Origin
  • 2.Document the Process
  • 3.Build for the Show Me Moment

Intelligence

Principles 4 to 7

Where most firms discover how far they are from defensibility. Screening that matches the sophistication of the content, component-level decomposition, forward-looking regulatory intelligence, and language-evolution awareness. This is the sophistication problem.

  • 4.Match the Sophistication
  • 5.Decompose Before You Evaluate
  • 6.Anticipate Interpretation
  • 7.Account for Language Evolution

Operations

Principles 8 to 10

Where principles become provable behaviors. Decision explainability for every approval, structural separation of the screening function from the approval function, and version control for everything an examiner might ask to see.

  • 8.Explain Decisions
  • 9.Separate Functions
  • 10.Version Everything

Evolution

Principles 11 to 12

Everything else decays without these. Stress-testing and review cycles built into the governance architecture itself. A framework that cannot evolve is already decaying.

  • 11.Stress-Test
  • 12.Evolve the Framework

Why now

There is a window, and it is open now.

No public enforcement action has yet targeted AI governance at a registered investment adviser. No binding guidance defines what reasonably designed supervisory procedures look like when AI is in the workflow. That statement has a short half-life.

The firms that build documented governance during this window will have years of audit trail when standards formalize. The first firms an examiner sees doing it well quietly set the standard the rest of the industry inherits. Edition 1.0 is not the last word. It is the first credible one.

The authors

Written by the people who built the system and run the firm.

One author operates a practicing SEC-registered advisory firm. The other built the AI screening infrastructure that governs its content. Every principle emerged from that intersection, tested against production before it was written in prose.

Brandon Veldman,CFA
Stefan Whitwell,CFA, CIPM

Frequently asked questions

What is If Done Right about?
If Done Right is a book and framework for governing artificial intelligence inside SEC-registered investment advisory firms. It presents the twelve IDR Principles, organized in four categories, that define what a defensible AI governance process requires. It was written from inside a practicing registered investment adviser and tested in production before it was written down.
Who should read it?
The primary reader is the chief compliance officer at an SEC-registered firm. The book is also written for firm owners and principals, who control the budget, authority, culture, and attention that AI governance requires. Part V is addressed directly to owners.
What are the IDR Principles?
IDR stands for If Done Right. The twelve IDR Principles are decision frameworks, not a compliance checklist. Each one is operationally testable, maps to a specific question an examiner could ask, and identifies the evidence a firm must be able to produce. They are organized in four categories: Foundation, Intelligence, Operations, and Evolution.

Be first to read it

The window is open now.Be ready before it closes.

If Done Right publishes soon. Leave your email and we will send you one note the day it is available, along with early access to the working audit checklist from the book.

Written for the chief compliance officer having the week the policy manual did not plan for, and the owner who controls the budget, authority, and attention to fix it.

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