Do You Have to Retain AI Meeting Transcripts?

The short answer

If an AI-generated transcript or summary documents advice, informs a recommendation, or evidences a client communication, it is likely a record — and the tool that produced it does not change that.

Cooley's analysis for registered advisers is the most direct published treatment and concludes that Rule 204-2's definition of a record captures AI-generated transcripts whether firms realise it or not, adding that "the analysis is more complex than most firms have recognized."

Why firms get this wrong

Because the decision gets made by procurement rather than by compliance. A meeting tool is adopted for convenience, the transcription feature is switched on by default, and no one classifies the output. The absence of a decision reads, later, as a decision.

The second reason is category confusion. Firms reason about the tool — is a notetaker a records system? — when the rule reasons about the output. A single tool can produce outputs that are records and outputs that are not, in the same meeting.

The fact patterns

Retention arguments are strongest where the output influenced advice.

• Summary that informed a recommendation. Strongest case for treating it as a record. It is part of the basis for advice.
• Transcript of a client meeting where advice was given. Strong. It evidences a client communication.
• Action items generated and then executed. Strong, because the output drove firm activity.
• Draft follow-up email later sent. The sent communication is plainly a record; the draft's status depends on the firm's analysis.
• Internal-only summary of an internal meeting with no client advice. Weakest, but not automatically outside scope.

None of these are legal conclusions for your firm. They are the shape of the analysis, which is why the analysis needs doing rather than assuming.

What consistency requires

Whatever the firm decides, the practice has to match the policy and the vendor has to be able to support it.

Three failure modes recur. A policy that says transcripts are retained, against a vendor that purges after 90 days. A practice of deleting transcripts, with no written analysis of why they were not records. And a retention policy that covers the primary meeting tool while three other adopted tools also generate transcripts silently.

The third is the most common, and it is the reason the inventory step comes before the retention step.

Questions for your vendor

• What exactly is retained — audio, transcript, summary, action items, drafts?
• For how long, and can we set the period?
• Can you produce all outputs for a named client across a date range?
• Are outputs stored as generated, or regenerated on request?
• What happens to records when we terminate?

One clarification about regulatory sources

FINRA's 2026 report addresses generative AI broadly and does not issue notetaker-specific guidance. Where published commentary applies FINRA's recordkeeping expectations specifically to meeting-notetaking tools, that is a reasonable analyst inference rather than a direct regulatory statement, and it is worth knowing which is which before repeating either in a policy document.