AI as an Attributable Representation Channel: When AI-Mediated Suitability Claims Become a Governance Failure
Year: 2025
Type: article
Abstract: Public-facing AI assistants increasingly provide guidance to consumers on financial products, risks, suitability, and comparative options, often in high-intent decision contexts. While firms typically do not author or control these systems, representations relating to suitability and risk may nonetheless create attribution or accountability exposure under existing conduct and consumer-protection regimes. This paper examines a governance gap emerging in financial services: supervisors and internal audit functions increasingly expect firms to evidence oversight of AI-mediated representations, yet most institutions lack audit-grade artifacts demonstrating such monitoring. Using an illustrative scenario, the paper shows how Reasoning Claim Tokens (RCTs) can function as evidentiary control objects that document repeatable omission of suitability constraints without requiring access to AI model internals or operational control over third-party systems. The analysis situates AI-mediated omission risk within established conduct-risk and suitability doctrines and clarifies the governance implications of detectability, repeatability, and foreseeability.
Author: de Rosen, Tim
Language: English
Subfield: Law
Field: Social Sciences
Domain: Social Sciences
Open Access status: green
OpenAlex ID: W7117871982
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