Fiduciary care, documented at the moment it matters.
Wealth decisions don't have a 24-hour reversal window. Once a discretionary trade settles, an IRA liquidation completes, or a beneficiary change is recorded, the question becomes evidentiary: did the client freely choose this, with intact understanding, free of undue influence? RTScale captures decomposed affect indicators at consequential moments — elder-flag situations, large distributions, discretionary authorizations, capacity-relevant decisions — and gives compliance and fiduciary teams cryptographically signed evidence that survives a six-year retention window. The Reg BI Care Obligation documentation writes itself.
Margaret, 81, calls in to liquidate her IRA.
Fifteen years of client-advisor history. Today's request doesn't match the pattern. This is the moment Reg BI's Care Obligation and FINRA 2165's reasonable-belief standard want documented — and the moment most firms still document as a paragraph in a CRM note.
The documentation your reviewer reads. The summary your client receives.
Reg BI's Care Obligation requires documented best-interest assessment. The dual-template report turns one signature into two deliverables — written in different registers, for different readers, from the same underlying evidence.
What we noticed, and why we paused
Dear Margaret,
I wanted to write to you directly about our call last Tuesday. You called asking us to move $85,000 from your IRA, urgently, and you asked us not to involve your family. Our conversation gave me reason to want to pause — your tone, your hesitation, the way you mentioned what "they" had told you — and I'm so glad we took that pause together.
Our firm has a process for moments like this one. We placed a 15-business-day pause on the distribution and we reached out to your daughter Lisa, who you had asked us to keep in mind as a trusted contact. She helped us all see what was actually happening: someone was pretending to be your grandson and pressuring you to send money to them.
You did not do anything wrong, Margaret. They targeted you precisely because they knew you would want to help. The pause our firm took is a process designed for exactly this kind of moment, and you can ask me about it any time.
Your IRA is intact. We have filed reports with the police and with our regulator. We'd like to chat soon about whether your trusted-contact instructions still feel right to you — sometimes, after something like this, people want to adjust them.
I'm here whenever you'd like to talk. — John
Reg BI Care Obligation — engagement documentation
som:auth:8a3f...d2c1 · sealed T+0 10:45:23 EDT · Adjudication class · 30s
Deep Scan Different regulatory framings. The same signature.
Wealth decisions across the lifecycle that share the "did the client freely choose this" question — and the documentation burden that comes with answering it.
Elder financial exploitation
The flagship case for wealth firms. Documented reasonable belief unlocks the temporary hold, the trusted-contact outreach, and the SAR narrative. Margaret's case in §01 is the worked example — the same pattern applies across the elder-flag matrix.
Fiduciary engagement & Reg BI care obligation
Routine engagement documentation, not exception-only. Each consequential recommendation generates a signature attesting to client engagement, understanding, and care assessment. The Care Obligation paragraph in your case file becomes evidence-backed instead of narrative-only.
Discretionary trade authorization
Discretionary authority requires documented client consent for each trade or for a documented standing authorization. Annual or triggered reauthorization with a SoM signature provides cryptographic evidence of an informed renewal — particularly important for accounts that have changed in size or risk profile.
Capacity-relevant decisions
Not a clinical capacity assessment — observable affective indicators that complement existing capacity protocols. Triggers a more thorough review process rather than rendering a decision. For trust modifications, beneficiary changes, or large gifting decisions where capacity may be in question.
Beneficiary changes & large distributions
Beneficiary changes are the most common vector for undue influence on retirement accounts and insurance products. A new caregiver appears; suddenly a beneficiary change request arrives. The act is the client's; the influence may not be. SoM at the moment of change provides retrospective evidence that supports families and courts later.
What the signature documents, by rule.
Wealth regulation maps unusually cleanly to "did the client freely choose this." Each major rule has a specific question; the dual-template report answers it in the appropriate register.
What your CCO asks first.
Pulled from working sessions with wealth-firm CCOs, compliance counsel, fiduciary engagement leads, and elder-protection program owners.
Signature events flow into your CRM as structured records via REST webhook or message queue. Reference connectors exist for Salesforce FSC, Black Diamond, and Orion; the rest is a 1-2 week integration scoped during onboarding. The signature becomes part of the case file, attached to the relevant household/account/recommendation record. Your existing workflows for SAR drafting, FINRA 4512 outreach, and Reg BI care documentation pull from the signature's pre-populated language — they don't change.
Affective capture is disclosed at onboarding in the firm's relationship disclosure — the same document where recording and recordkeeping practices are already disclosed. The capture surface is the same camera frame the client is already on for a video consultation, so it's not a separate or surprising surface. Clients can decline; the firm's policy then routes to a traditional documentation path. We provide template disclosure language reviewed by securities counsel.
No. The signature outputs decomposed observable affective indicators — distress, prosody, gaze, baseline divergence. It does not output a capacity ruling or a clinical diagnosis. The dual-template reports are written in this register on purpose. For capacity-relevant decisions (use case 04), the signature triggers your firm's existing capacity-review process; it does not substitute for it. Explicit disclaimer language is included in framing materials and in the client-facing report.
The signature provides the documented basis for the 4512 outreach. Margaret's case in §01 shows the flow: signature-indicated reasonable belief → 2165 hold → 4512 trusted-contact engagement, with the documentation chain single-sourced. Your existing trusted-contact registration and outreach workflows are untouched; the signature replaces the unstructured "advisor noted concern in the call" paragraph with structured evidence.
The signature is retained per FINRA recordkeeping (6 years for most artifacts; longer for some). The signature itself is a small cryptographic artifact containing decomposed indicators and provenance — not raw biometric data. The underlying biometric capture can be cryptographically erased on client request immediately (key revocation), while the signature chain remains valid for audit. For EU/UK clients exercising GDPR Article 17, the erasure is mathematical: signature verifiable, biometric provenance unverifiable.
The reviewer-facing report's pre-populated language is structured to drop into SAR Part V narrative. Specifically aligned to FinCEN FIN-2022-A002 typology language for elder exploitation cases. Your AML / SAR team retains drafting and filing authority — the signature provides the documented affective indicators and the reasonable-belief language, not the filing itself.
The signature is a verifiable cryptographic artifact with hardware-rooted attestation. It survives the standard evidentiary chain. We've consulted with securities arbitration counsel on the framing: the signature is presented as documented observable affective indicators consistent with the firm's reasonable-belief standard, not as a definitive proof of coercion. Arbitrators and courts have accepted similar affective-evidence formats. We provide expert-witness support for matters where firms request it.
The refusal is a documented event (Presence-class signature with the client's explicit decline, signed and timestamped). Your firm's policy then decides the path — traditional documented advisor notes, supervisor review, or proceed with the transaction noting the decline. We do not recommend that refusal alone block a transaction; that creates an adverse-selection problem. Most firms route refusal-on-elder-flag-trigger to senior compliance review.
Bring your hardest elder-flag case to a 30-minute demo.
The case your 2165 team can't quite document. The Reg BI review that came back asking for "more detail in the care obligation paragraph." The trusted-contact outreach where the advisor's note didn't survive arbitration. We'll walk through how the same situation produces a signed signature, a dual-template report, and a six-year-retention artifact your reviewer reads in two minutes.