Artificial intelligence continues to evolve quickly, offering new ways to improve efficiency, generate ideas and streamline everyday tasks. But using AI for ESI business also comes with important responsibilities around client confidentiality, cybersecurity, advertising, recordkeeping and supervision.
ESI recently issued updated guidance to help financial professionals and their teams understand where and how AI can appropriately be used.
Keep Confidential Information Out of Unapproved AI Tools
Never enter sensitive client or prospect information into an AI tool unless the specific application and use case have been reviewed and approved by ESI. This includes names, account information, financial plans, statements, holdings, transactions and other personally identifiable information.
The same principle applies to confidential or nonpublic information about your business, ESI or National Life Group.
Be particularly mindful of AI-powered meeting assistants and transcription tools. Do not enable an AI meeting tool during client or prospect interactions unless it has been approved by ESI for that specific use. This also applies when joining meetings hosted by someone else—if an AI notetaker is active, do not share client information or ask the host to turn it off.
Where AI Can Help
When no confidential, client, prospect, Firm or nonpublic information is involved, appropriate uses of approved AI can include:
- Brainstorming generic marketing or client appreciation ideas
- Creating internal meeting agendas
- Improving grammar in non-client-specific content
- Developing generic social media posting schedules, subject to Firm advertising review
Conversely, unapproved or open-access AI tools should not be used to summarize client meetings, analyze financial plans or account statements, create client-specific financial analysis, produce investment research, make securities recommendations, or rank or target clients and prospects.
AI Is an Assistant, Not an Autopilot
AI-generated information can be inaccurate, incomplete, outdated or even fabricated. Treat AI as a drafting or research aid—not a replacement for your professional judgment.
Any AI-assisted output must be independently reviewed before it is used. Ultimately, you remain responsible for ensuring the content is accurate, complete, fair, balanced and compliant.
Before You Use an AI Tool for ESI Business
Remember one simple rule: an AI application, plug-in, browser extension, transcription service, embedded assistant or agentic tool must be reviewed and approved by ESI for the intended use case before it is used for Firm business.
As AI capabilities continue to change, existing ESI requirements around data security, advertising approval, correspondence, investment tools, supervision and email communication continue to apply. Using AI does not change your responsibility for the generation, review, approval and use of the resulting content.
Questions? Refer to Field Notice 2026-18 or contact the ESI Compliance team at 800-344-7437 or esicompliance@nationallife.com
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