CLHEAR Open source
Turns raw regulatory text into compliance blueprints, each item traced to its clause. Help make it the industry standard.
CLHEAR on GitHub
The story
One firm. One regulation. Eight steps.
Follow Example Markets, a fictional US broker-dealer, from the text of one rule to a plan that closes the gap. Switch the rule at any time.
EMExample Markets · starting with FINRA Rule 2210
Map.
Pick one rule, describe your firm, and get the program you need.
01Where do I start?
Start with one regulation, not the whole rulebook.
Pick the regulation or licence that matters now. CLHEAR keeps its original text, clause by clause, with the source and date.
SourcesL1
FINRA Rule 2210
Communications with the Public
FINRA Rules · Last amended 16 August 2019
2210(d)(1)(B)“No member may make any false, exaggerated, unwarranted, promissory or misleading statement or claim in any communication.”
Kept verbatim, with a copy stored for citation
Picture: a shelf of the three starting regulations with the selected one pulled out, showing its official reference, its date and the verbatim text of one clause.
02What makes it apply to us?
Tell CLHEAR who you are. Only this leaves your hands.
Countries, licences, products, clients and channels. These facts decide which obligations apply. Controls, owners and evidence stay in your own systems.
Profile · Example MarketsL4
- Countries
jurisdictions - United States
- Licences
authorisations - FINRA member broker-dealer
- Products
products - StocksETFs
- Clients
customer_base - Retail
- Channels
channels - Mobile appPaid influencers
Only these facts go to CLHEAR. Controls, owners and evidence stay in your systems.
Picture: the example firm's profile, with its countries, licences, products, clients and channels lighting up as they are chosen.
03What does compliance require of us?
The program you should have, traced to each clause.
CLHEAR lists what your firm must have: policies, roles, committees, systems and processes. This is your reference blueprint, and every item links back to its clause.
Reference blueprint · FINRA 2210L6
2210(b)(1)(A)A principal approves each retail communication before use
2210(d)(1)Keep communications fair and balanced
2210(d)(6)(B)Disclose testimonials, including paid ones
2210(b)(4)(A)Keep each communication with its dates of use
3110(b)(1)Keep written supervisory procedures
Principal approval before useProcess · 2210(b)(1)(A)
Content standardsDocument · 2210(d)(1)
Testimonial disclosuresDocument · 2210(d)(6)(B)
Communications archiveSystem · 2210(b)(4)(A)
Supervisory proceduresDocument · 3110(b)(1)
What the rule requires
Picture: the reference blueprint. Each required item is drawn with a dashed periwinkle outline and linked to the clause it comes from.
Start with one regulation. We map it with you.
Scope a conformance projectCompare.
Map what you run today and see the gap, item by item.
04What do we already do?
The program you actually run, in the same language.
Your documents, systems, people and data feeds form the actual blueprint. It uses the same shapes, so the two can be compared item by item.
Actual blueprint · Example MarketsReg42 OS
DocumentsDocument store
SystemsSocial media archive
Data feedsTeam chat archive
DocumentsShared drive
Chat approvalsProcess · from Team chat archive
Marketing standards v4Document · from Document store
Nothing in placeDocument
Archived posts, dailySystem · from Social media archive
Nothing in placeDocument
Legacy influencer spreadsheetAsset · from Shared drive
What you have in place
Picture: the actual blueprint. The firm's documents, systems and data feeds fill the same slots in solid turquoise. Empty slots show what is missing, and one extra item is marked as surplus.
05Where are we short?
Your gap analysis, item by item, with the reason.
The two blueprints overlay. Covered items fill in, gaps stay open, and mismatches and extras are marked.
Gap analysis · FINRA 2210Reference × actual
2 covered2 gaps1 mismatch1 surplus
Principal approval before use2210(b)(1)(A) · Approved in chat, with no record before useMismatch
Content standards2210(d)(1) · Matches 2210(d)(1)Covered
Testimonial disclosures2210(d)(6)(B) · Posts do not say they are paidGap
Communications archive2210(b)(4)(A) · Each post kept with its dates of useCovered
Supervisory procedures3110(b)(1) · Procedures do not cover influencersGap
Legacy influencer spreadsheetNot traced to any clauseSurplus
Picture: the two blueprints overlaid. Covered items are filled, gaps stay empty, and the mismatch and the surplus item are marked, each with its reason.
Start with one regulation. Compare it on your own firm.
Scope a conformance projectComply.
Plan the work, prove it with evidence, and stay current.
06What do we do next?
A plan for complete compliance, not a report.
Each gap becomes a task with an owner across the three lines of defence: generate a document, assign a role, install an app or run a workflow.
Scope a conformance projectAction plan · FINRA 22104 tasks
1st line · the business2nd line · compliance3rd line · independent review
Generate a documentAdd influencers to the supervisory proceduresGapSupervisory procedures · 3110(b)(1)HCHead of Compliance2nd line
Install an appRoute every influencer post for approvalMismatchPrincipal approval before use · 2210(b)(1)(A)HMHead of Marketing1st line
Run a workflowCheck testimonial disclosures before postingGapTestimonial disclosures · 2210(d)(6)(B)HMHead of Marketing1st line
Assign a roleName an independent reviewerGapSupervisory procedures · 3110(b)(1)IAInternal Audit3rd line
Picture: the action plan. Each gap becomes a task with an action type, an owner and a line of defence.
07How do we show it’s done?
Every obligation, answered with evidence.
Evidence flows back from production onto the item it proves. The audit trail records who did what, and why.
Evidence · Principal approval before useAudit trail
Principal approval before useProcess · 2210(b)(1)(A)MismatchCovered
From production
- Post approved before useInfluencer review app · 3 Sep 2026
- Approver and date archivedSocial media archive · 3 Sep 2026
- Next program review bookedWorkflow · Sep 2027
Route every influencer post for approvalDoneHMHead of Marketing
- Solon checked the postWhy: against 2210(d)(1)
- Registered principal approved itWhy: fair and balanced, before first use
Picture: evidence arriving from production onto one item, which turns covered, while its task moves to done and the audit trail records who approved it and why.
Interlude · Solon
Ask the example firm.
A complete, traced blueprint makes precise answers possible. Solon is the AI model inside Reg42 OS. It answers from the firm’s own blueprint graph and shows the trail behind every answer.
- Hosted in your environment. The model runs inside your cloud account, next to your data.
- Grounded in your graph. Obligations, blueprint items, evidence and clauses, all linked.
- Fed by apps and agents. They keep the graph current with live data.
Solon · Example MarketsSIMULATED
What does FINRA require of us for influencer posts?
- Reading the firm profile
- Resolving the obligations that apply
- Walking the blueprint graph
- Checking evidence and clauses
Posts that influencers make for Example Markets count as its retail communications under Rule 2210. A registered principal must approve each one before use, the content must be fair and balanced, testimonials must carry the required disclosures, and each post must be kept with its dates of use. Rule 3110 asks for written procedures that cover all of this.
ObligationsApprove each retail communication before useKeep communications fair and balancedDisclose testimonials, including paid onesKeep each communication with its dates of useKeep written supervisory procedures
Blueprint itemsPrincipal approval before use MismatchContent standards CoveredTestimonial disclosures GapCommunications archive CoveredSupervisory procedures Gap
EvidenceNone yet
ClausesFINRA Rule 2210(b)(1)(A)FINRA Rule 2210(d)(1)FINRA Rule 2210(d)(6)(B)FINRA Rule 2210(b)(4)(A)FINRA Rule 3110(b)(1)
A replay on a fictional firm with simulated data. It is an example, not a live client.
08What happens when the rule changes?
When the rule changes, see exactly what changes for you.
A changed clause travels up through the blueprint to the one task it affects, with a named owner.
Change feed · FINRA 2210Watched
- 1Clause changes SIMULATEDFINRA Rule 2210(d)(6)Amendment published
- 2Obligation updatesDisclose testimonials, including paid ones
OBL:finra-2210#d-6-b - 3Item flaggedTestimonial disclosuresNeeds new wording
- 4Task createdUpdate the disclosure wordingHMHead of Marketing
Picture: a change feed. A clause change updates an obligation, flags one blueprint item, and creates one task for a named owner.
Zoom out
Start with one. Add the next on the same path.
Each regulation adds its blueprint, and the blueprints join into one program. An item that serves more than one rule appears once.
FINRA 2210
FINRA 5310
EU AI Act
One programExample Markets
- Principal approval before useFINRA 2210
- Content standardsFINRA 2210
- Testimonial disclosuresFINRA 2210
- Communications archiveFINRA 2210
- Supervisory proceduresFINRA 2210 + 5310
- Execution quality monitoringFINRA 5310
- Quarterly execution quality reviewFINRA 5310
- Review by security and order typeFINRA 5310
- Comparison with competing marketsFINRA 5310
- Risk management processAI Act
- Technical documentationAI Act
- Automatic event logsAI Act
- Human overseerAI Act
- Fundamental rights impact assessmentAI Act
Start with one regulation. Grow from there.
Scope a conformance project