Can a financial advisory or RIA firm sell its data to AI?

Mode's 15+ rule for finance, Regulation S-P limits on client information, and how many U.S. investment-advice firms qualify.

Last updated 4 sources cited1 min read

Short answer: Possibly, for firm operating records. Mode lists finance at 15+ employees. Client nonpublic personal information is restricted by Regulation S-P, so client files stay out. Census counts 836 U.S. investment-advice firms with 15+ employees and 483 with 30+.

On this page
  1. Size
  2. Regulation S-P
  3. What could be in scope
  4. Frequently asked questions
  5. Sources

Size

Mode lists minimum team sizes of 10+ employees for legal, 15+ for accounting, medical and finance, and 50+ for all other businesses, for companies based in the US, Canada, the UK or Australia with several years of records they own (Mode). micro1 asks for 30+ employees, mostly English data, and says it is prioritizing US companies (micro1).

Industry (U.S. firms, 2022)All firms15+ staff30+ staff50+ staff100+ staff
Investment advice (NAICS 523930)22,245836483367272

Source: U.S. Census Bureau, Statistics of U.S. Businesses 2022, detailed employment sizes. Firms (enterprises) by paid employees; contractors are not counted. Each column sums the Census size classes at or above that size.

Regulation S-P

Regulation S-P sets limits on disclosing nonpublic personal information to nonaffiliated third parties, generally requiring notice and a chance to opt out unless an exception applies (17 CFR Part 248, Subpart A). A data license is a disclosure to a nonaffiliated third party.

What could be in scope

  • Operations: onboarding workflows, rebalancing procedures, compliance calendars, with client data removed.
  • Internal research process and investment-committee procedures (check for material nonpublic information).
  • Training and marketing records.

This is general information, not legal advice. Talk to your own attorney or compliance advisor before you share or license any records.

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Frequently asked questions

Are we 'finance' for Mode?

Mode lists finance at 15+. Ask how it classifies your firm if you also sell insurance, since insurance is on its not-a-fit list.

Do custodial records count as ours?

Custodian platforms have their own terms. Check before exporting.

Sources

  1. Mode / BizBuyData referral pagebizbuydata.com
  2. micro1 company referral pagemicro1.ai
  3. U.S. Census Bureau, Statistics of U.S. Businesses 2022, detailed employment sizeswww2.census.gov
  4. 17 CFR Part 248, Subpart A (Regulation S-P) (Cornell LII)law.cornell.edu

Referral-fee disclosure: we may be paid by a program if your company signs with it after using this site. General information only, not legal advice.

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