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Finding F-05 · WP-05 · verified August 2026

In embedded deployment the broker carries the obligations

In embedded deployment, the binding obligations sit with the distributing broker — so the analytics vendor’s real competitive weapon is exportable compliance evidence, not disclaimers.

ORIN Labs WP-05 · F-05 · as of August 2026
Basis

Regulation Best Interest and NASD Notice to Members 01-23; FINRA Rules 2210, 2214 and 3110 with the 2026 Regulatory Oversight Report; ESMA public statement on AI (May 30, 2024); DORA Art. 30.

Method

Doctrinal analysis of primary sources — statutes, regulations, adopted rules, case law and official guidance — supplemented by the enforcement record and by regulator publications through August 2026. Each 2024–2026 development was verified against the issuing body’s own publication or contemporaneous professional reporting. Argued in §2 of the paper.

Argued in

§5, §7, §11.5 of AI Decision Support and the Advice Line (WP-05).

As of

August 2026. The regulatory record moves; this finding is dated rather than presented as timeless, and it is revised or withdrawn — never silently amended — when the record changes. Corrections: labs@tryorin.xyz.

Cite this finding

ORIN Labs (2026). F-05: In embedded deployment the broker carries the obligations. In AI Decision Support and the Advice Line, ORIN Labs Research WP-05. https://tryorin.xyz/labs/findings/embedded-obligations-sit-with-the-broker. August 2026.

Quoting the sentence above verbatim is the intended use. It carries its own jurisdiction, method and date so that it stays true when it is read away from this page.

The other findings in WP-05

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