Comma Compliance

AI activity retention

An employee just used ChatGPT to draft a client email.

Was that interaction retained as a business record?

Comma captures ChatGPT Enterprise activity through OpenAI's own Compliance Platform — the official integration OpenAI built for regulated customers.

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If an interaction qualifies as a business record, the tool used to produce it doesn’t change that.

SEC Rule 17a-4, FINRA Rule 4511, and the Investment Advisers Act recordkeeping requirements were written around the nature of the content, not the channel it traveled through. The question is not where the activity happened. The question is whether the firm can produce the record.

That same principle drove the off-channel messaging enforcement actions involving WhatsApp, Signal, and iMessage. Employees conducted business through channels firms were not retaining. The result was not a new rule. It was enforcement of existing ones.

ChatGPT introduces a new interface, but the recordkeeping framework is already in place.

Comma captures the underlying AI interaction, including prompts, responses, files, and related context.

What Comma captures from ChatGPT Enterprise

  • Conversations: user prompts and model responses
  • Uploaded files attached to a session
  • Workspace GPT configuration and metadata
  • Memories and the workspace user directory

All of it delivered as OpenAI’s immutable, append-only compliance logs and routed into the same tamper-proof archive as your other channels.

Why the architecture matters

For your compliance team

  • Provider-sourced records

    Records come directly from OpenAI's own immutable Compliance API log — not a screenshot, not a manual export. The data is append-only by design and examiner-ready from the moment it lands in the archive.

  • One archive, one review queue

    ChatGPT activity lands alongside your other 35+ channels. One supervision workflow covers everything — compliance teams don't learn a separate tool for AI.

For your IT team

  • No endpoint agent

    No browser extension, no device software, nothing to deploy. Comma authenticates to OpenAI's Compliance API with admin credentials. That's the entire integration surface.

  • Admin-controlled

    A ChatGPT Enterprise administrator enables the Compliance Platform once. From that point, capture runs automatically across the workspace — no per-user setup.

For your employees

  • Nothing changes

    Capture happens at the API layer, not on the device or in the browser. Employees use ChatGPT exactly as they do today — no new app, no workflow change, no visible difference.

  • No manual forwarding

    Users do not need to save transcripts, export conversations, or remember retention procedures. The record is created automatically.

FAQ about ChatGPT compliance archiving

Do we need ChatGPT Enterprise for Comma to capture activity?
Yes. ChatGPT Enterprise is where OpenAI exposes the Compliance Platform — the official, admin-enabled path Comma integrates with. On consumer and Team tiers the API does not exist, so there is no provider-supported way to capture the activity.
What exactly does Comma capture from ChatGPT?
Conversations (user prompts and model responses), uploaded files attached to a session, workspace GPT configuration and metadata, memories, and the workspace user directory — all delivered as immutable compliance logs and landed in the same archive as your other channels.
What about employees using free or Team-tier ChatGPT?
That activity cannot be captured through the compliance API, because OpenAI does not expose it below Enterprise. Treat it the way you treat an unmonitored messaging app: it is an off-channel risk. The practical fix is a written policy that standardizes regulated AI use on ChatGPT Enterprise, where capture is possible.
Does ChatGPT activity go into the same archive as our other channels?
Yes. ChatGPT activity is captured into the same tamper-proof, exam-ready archive as WhatsApp, Signal, iMessage, email, and the rest of your 35+ channels: one archive, one supervision queue, one export. Compliance teams do not learn a separate tool for AI.
Is the captured data examiner-ready?
Yes. The data comes from OpenAI's own immutable compliance log, captured in structured form with timestamps and metadata intact, and retained in WORM-compliant storage that supports SEC Rule 17a-4 and FINRA Rule 4511. When an examiner asks for a date range or an individual, the records are searchable and exportable on demand.

ChatGPT is already a front-office channel.

Capture it the same way you capture everything else — through OpenAI's official Compliance Platform, into one exam-ready archive.

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All 35+ Channels

ChatGPT is one of the 35+ channels Comma archives. From collaboration tools to email to messaging apps, Comma has you covered.

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