Samples /
RIA /
Deep dive
/
Independent-verifier declaration
Deep dive — methodology
Independent-verifier declaration — why the control plane cannot reside within the entity being regulated
The signed statement at the end of every $499 Snapshot. Not a checkbox — a personal, standing attestation by Kevin Luddy as principal of contrarianAI LLC. Here is what it says and why the specific words matter.
The declaration verbatim
"I, Kevin Luddy, as principal of contrarianAI LLC, personally attest that:
1. contrarianAI is not an employee, contractor, equity holder, or vendor of the audited RIA or any of its portfolio-management platform vendors (Orion, Envestnet, Black Diamond, Tamarac, Addepar, or any similar), robo-advisor engines (Betterment for Advisors, Wealthfront, SigFig, or any similar), TAMP / OCIO providers, or third-party AI-recommendation vendors.
2. Assessment tools (distributional-shape sensor, retrieval-auditor, tool-call-grader, prompt-drift-sensor, predictor-corrector, router-drift-sensor) use deterministic classical-statistics methods -- KL divergence, chi-square, variance-ratio, signal-detection ROC, Cohen's kappa -- applied to the audited RIA's AI-decision output streams. The analytical pipeline itself contains no AI. Model families used for any auxiliary tasks (drafting-assist, formatting) are distinct from those in production at the audited RIA.
3. This Snapshot is based on the data-sample submitted by the buyer. Changes to the audited RIA's infrastructure after the Snapshot date are outside this Snapshot's scope.
4. Underlying audit evidence is retained for the Snapshot horizon and will be made available for legitimate SEC / State securities-commissioner / FINRA / auditor / counterparty inquiry with appropriate legal process."
Sample declaration — signed Kevin Luddy, Principal, contrarianAI LLC, 2026-07-22
The four clauses, unpacked
- No entanglement. Not an employee, contractor, equity holder, or vendor. The independence is structural — not a policy claim.
- Distinct methodology. The analytical pipeline is deterministic classical statistics -- peer-reviewed methods that predate the AI era by 50 to 125 years (Kullback-Leibler 1951, Fisher F-test 1920s, chi-square 1900, Cohen's kappa 1960). No AI generates findings, conclusions, or citations. Different retention pipeline. The verifier is not merely re-running the platform vendor's own instrumentation, and defense counsel cannot attack the audit as "AI-black-box" because no AI sits in the audit path.
- Bounded scope. Data submitted at Snapshot time. Post-Snapshot changes are not covered. Honest scope prevents false-positive comfort.
- Retention + production stance. Underlying evidence retained; available for legitimate inquiry with appropriate legal process. Not an offer to hand over records on demand — a statement of the discipline.
Why "personally attest" matters
Kevin Luddy's name is on the signature. Not "contrarianAI LLC." Not "the audit team." A named principal, standing behind the statement. That is how attestations that survive challenge at the SEC exam desk, in a FINRA enforcement matter, in a state securities-commissioner action, or in client arbitration are structured — a named person, addressable, cross-examinable.
The Big-4 accounting and consulting firms deliver this discipline at $200K-$1M+ per engagement. The $499 Snapshot does the same discipline at 5-10% of the price by scoping tightly to one AI surface + producing one determination + retaining evidence.
What "control plane" means
A control plane in systems engineering is the layer that observes and governs another layer's behavior, from outside that layer. Applied to an RIA using AI recommendation tooling:
- The platform vendor's or robo-advisor vendor's own monitoring is inside the vendor's plane. Vendor cannot credibly grade its own homework.
- The firm's own compliance and IT monitoring is inside the firm's plane. Same principle.
- An independent verifier — distinct entity, distinct methodology, distinct retention — is outside both. That is the control plane.
"We use our vendor's compliance module" is the modal answer regulators reject. The Snapshot exists so that a defensible answer — independent verifier, signed declaration, retained evidence — can be produced at $499.
$499 Snapshot. 3 business days.
Signed independent-verifier declaration on your firm's actual AI recommendation surface. Retained evidence. Named principal.
Buy $499