FINRA 25-07 is a FINRA notice that addresses how firms preserve and access digital communications and online content for compliance and audit purposes. This includes recordkeeping of dynamic websites, social media posts, electronic communications, and other digital content properly archived and easy to access when needed for audits, investigations, or regulatory reviews.
What makes FINRA 25-07 different is that it goes beyond traditional recordkeeping requirements. It reflects a broader effort to modernize compliance expectations. As a result, it helps firms adapt to the way business is conducted today while still maintaining strong investor protection and regulatory oversight.
FINRA notice 25-07 discusses how traditional recordkeeping systems were not designed with modern digital channels in mind, which may allow content to change or be updated dynamically, be personalized for each user or be created dynamically by algorithms or other technologies.
Financial communications have become more dynamic and personalized. McKinsey reports a rapid growth in AI-driven personalization across digital experiences, with 71% of consumers expecting companies to deliver personalized interactions, and 76% becoming frustrated when it didn’t happen.
Content shown to one web user might differ from what others see based on geography, browsing behavior, and other factors. In many cases, there is no single static record that accurately represents what each user experienced. This creates significant gaps between current FINRA regulations and the types of controls and preservation standards that modern digital communications now require.
“Dynamic data” refers to digital data that is not static and therefore not the same for every user. Modern websites now include data filters, changing carousels, calculators based on market rates, embedded content, and much more. Modern communication can be personalized based on user profiles, geolocation, and behavior. As much as dynamic data can change through live feeds or changing input streams, content can also be created instantly by AI and chatbots. The data content is created from APIs, third-party widgets, scripts, and multiple backend systems. As a result, the information one user sees at one time can be completely different from what another user sees. This creates great challenges for traditional record-keeping and compliance frameworks.
Current FINRA guidance underlines a growing regulatory risk, as firms are still expected to demonstrate exactly what was communicated to investors, supervise those communications appropriately, and produce complete records on demand even as digital content evolves.
In practice, this means that static capture often leaves massive compliance holes – particularly for changing or personalized content or AI-driven conversations. The result is incomplete documentation and limited auditability that hampers full reconstruction of the customer journey. This can be particularly problematic when reviewing investigation and examination files during enforcement proceedings, making it hard to prove what was presented, when or if necessary disclosures and supervisory controls were enforced.
‘Replayability’ is now essential to achieving defensible compliance. More websites and applications are driven by live data, personalization engines, calculators, APIs, and AI-generated responses. Without the ability to replay these experiences in their original context, companies might struggle to fully meet the necessary regulatory inquiries.
For example, an investment calculator may generate different outputs depending on market conditions, customer inputs, or timing. A static screenshot alone may not provide enough evidence to demonstrate what an investor actually saw or how recommendations were presented.
Therefore, companies need to be able to:
Since the 2010s, dynamic information is the norm across most digital platforms. The rise of generative AI has accelerated the shift even further. AI chatbots, copilots and large language models can now produce completely original messages on the fly, meaning their responses can be changing each time a user interacts with them. This is one of the reasons that regulators like FINRA are re-evaluating whether classic recordkeeping policies will work for newer, less static types of electronic communication.
A recent survey of 500 IT and compliance leaders in financial services found that nearly all firms are increasing the use of AI across their communications environments. However, 88% reported difficulties managing and governing AI-generated communications and data effectively.
To successfully adapt to this new era of dynamic digital communications, firms should start asking critical questions about their recordkeeping strategy:
Technology will be critical in addressing these recordkeeping challenges. Choosing the right toolkit will help companies meet evolving regulatory expectations and consistently reduce compliance risk.
Hanzo solutions are designed to handle dynamic websites, collaboration platforms, social media, and other complex digital channels where content changes over time or differs between users.
Hanzo Chronicle captures and preserves dynamic web content and social media, including personalized pages, interactive elements, and changing website experiences that traditional archiving tools may miss.
Spotlight AI adds AI-powered analysis to help compliance teams be proactive and monitor non-compliance content real-time.
Together, these tools help firms preserve the full context of what users actually experienced across modern digital channels. To see Hanzo solutions in action, contact our team.
Content Team 
