Artificial Intelligence Use Policy
Orange Cat, LLC Last Updated: September 12, 2026
Orange Cat, LLC ("Orange Cat," "we," "us") uses artificial intelligence tools to work more efficiently and better serve clients. This policy explains how we use AI, how we don't, and how we protect your information when we do.
The three ways we use AI
We use AI for three distinct purposes, and nothing else.
1. Public research and lead programs. AI helps us research publicly available sources. For some clients, this research supports a recurring, scheduled lead program compiled from public sources based on criteria the client gives us. Each automated program is approved by a licensed professional before it is scheduled, is labeled as automated, and contains only public information. It never includes client positions, account data, internal notes or analysis, or individualized advice.
2. Drafting and refining communications. AI helps us draft emails based on public information, gives feedback or research on ideas we are developing, and makes our writing more concise. Every email or communication drafted this way is reviewed, edited, and sent by a person, and is subject to the same supervision and recordkeeping requirements as all our client communications.
3. Restricted — client information. AI is not approved for use in drafting or communicating anything involving client positions, client financial data, or any information that identifies a client. A person handles all of that without AI assistance.
Our commitments
A person is always responsible. AI helps us draft, organize, and research. AI does not make investment, insurance, or planning decisions. Any recommendation, document, or communication involving your positions, financial data, or identifying information is prepared and sent by a licensed professional without AI. The only automated messages we send are part of lead programs built from public sources, and a licensed professional approves them before scheduling.
Your personal information stays out of AI tools. We do not enter Social Security numbers, account numbers, statements, positions, or other identifying information into AI systems. When we use AI to build or test a process, we use sample data.
We do not allow our conversations to train AI models. The tools we use are configured so that our activity is not used to train or improve the vendor's models, and we keep our own records of any work product rather than relying on a vendor to store it.
AI sends nothing on its own without prior approval. The only messages AI sends autonomously come from the approved, labeled lead programs described above. Any other communication is sent by a person.
We're open about how we work. On request, we will explain how AI tools fit into our process and how we protect your information when we use them.
How we do not use AI
Making or automating investment, insurance, or financial planning recommendations
Storing, analyzing, or sharing client account data, positions, or personal information
Communicating anything about a client's positions, financial data, or identifying information
Sending communications to clients or prospects without prior approval
Solely making decisions about who we work with or the terms of our services
Data handling
We limit AI tool access to what a task requires. Where a tool can be given narrower permissions (for example, drafting but not reading email), we choose the narrower option. We review these settings periodically and update this policy as our tools and practices change.
Regulatory context
Securities and Investment Advisory Services offered through The Leaders Group, Inc. Member FINRA / SIPC 475 Springfield Ave, Suite 1, Summit, NJ 07901, 303-797-9080. Orange Cat, LLC is not affiliated with The Leaders Group, Inc.
Our use of AI is subject to the supervision, recordkeeping, and communication standards that apply to all of our advisory activities. Nothing in this policy changes the standard of care we owe you.
Questions
If you have questions about how we use AI, contact us at info@orangecat.llc or (201) 503-4170.
This policy describes our current practices and may be updated as technology and regulatory guidance evolve. It is not investment, legal, or tax advice.