Portal Walkthrough: Control 2.19 - Customer AI Disclosure and Transparency

Last Updated: January 2026 Portal: Copilot Studio, Custom Implementation Estimated Time: 2-4 hours initial setup

Prerequisites

• Disclosure templates approved by Legal/Compliance
• Customer communication channels identified
• Human escalation paths defined
• Disclosure tracking mechanism established
• Regulatory requirements mapped (SEC Reg BI, CFPB UDAAP, FINRA)

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Step-by-Step Configuration

Step 1: Define Disclosure Requirements by Zone

Zone	Disclosure Level	Timing	Human Escalation
Zone 1	Basic	On first interaction	On request
Zone 2	Standard	On first interaction + periodic	Readily available
Zone 3	Comprehensive	Every session + transaction	Proactive offer

Step 2: Create Disclosure Message Templates

Basic Disclosure (Zone 1):

You are interacting with an AI assistant. For complex questions,
ask to speak with a representative.

Standard Disclosure (Zone 2):

This is an AI-powered assistant designed to help with [purpose].
While I strive to provide accurate information, I recommend verifying
important details with a licensed representative. Would you like to
speak with a human agent?

Comprehensive Disclosure (Zone 3):

IMPORTANT: You are communicating with an AI assistant. This AI:
- Provides general information only, not personalized advice
- May not have access to your complete financial picture
- Cannot replace the judgment of a licensed professional

For financial advice, investment recommendations, or account-specific
questions, please speak with a licensed representative.
[Connect me with a representative]

Step 3: Configure Agent Greeting Topic

1. Open Copilot Studio
2. Select target agent
3. Navigate to Topics > Greeting (or create new)
4. Add disclosure message as first response
5. Add human escalation option

Example Topic Flow:

Trigger: Conversation start
  → Send disclosure message
  → Offer human escalation option
  → Continue to main conversation flow

Step 4: Implement Human Escalation Path

1. In agent topics, add escalation triggers:
2. User requests human
3. Sensitive topic detected
4. Low confidence response

5. Transaction threshold exceeded

6. Configure escalation action:

7. Transfer to Teams queue
8. Create support ticket
9. Provide callback option

Step 5: Configure Disclosure Tracking

Track that disclosures were delivered:

1. Log disclosure events:
2. Timestamp
3. User identifier (anonymized)
4. Disclosure type

5. Escalation offered/taken

6. Create compliance reports:

7. Disclosure delivery rate
8. Escalation rate
9. User acknowledgment (if required)

Step 6: Periodic Disclosure Reminders

For Zone 3 agents with extended conversations:

1. Create reminder topic:
2. Triggers after N messages or X minutes
3. Re-states AI nature

4. Offers escalation

5. Configure in conversation flow:

6. Track message count or time
7. Insert reminder at threshold

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Configuration by Governance Level

Setting	Baseline (Zone 1)	Recommended (Zone 2)	Regulated (Zone 3)
Initial Disclosure	Basic	Standard	Comprehensive
Periodic Reminder	None	Optional	Required
Human Escalation	On request	Readily available	Proactively offered
Disclosure Logging	Optional	Recommended	Required with retention
Acknowledgment	None	Optional	Consider requiring

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FSI Example Configuration

Agent: Client Advisory Bot
Environment: FSI-Wealth-Prod
Zone: 3 (Enterprise Managed)

Disclosure Configuration:
  Initial:
    Type: Comprehensive
    Message: |
      IMPORTANT DISCLOSURE: You are interacting with an AI-powered
      assistant. This AI provides general information only and does
      not provide personalized investment advice. For specific
      recommendations regarding your portfolio or financial situation,
      please speak with your assigned financial advisor.

      [Connect me with my advisor]

  Periodic:
    Trigger: Every 10 messages OR 5 minutes
    Message: |
      Reminder: You're chatting with an AI assistant.
      Would you like to speak with a human advisor?

  Pre-Transaction:
    Trigger: Before any account action
    Message: |
      Before proceeding, please confirm you understand this is an AI
      assistant. For personalized advice, please speak with an advisor.
      [I understand] [Connect me with an advisor]

Human Escalation:
  Triggers:
    - User says "human", "person", "advisor", "representative"
    - Confidence < 0.7
    - Topic: Investment recommendation
    - Topic: Complaint
    - Transaction > $10,000

  Action: Transfer to Teams "Wealth Advisory Queue"

  Fallback: Create callback request in Dynamics

Tracking:
  Log To: Dataverse - AI Disclosure Log
  Retain: 7 years
  Fields: SessionId, Timestamp, DisclosureType, EscalationOffered, EscalationTaken

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Validation

After completing these steps, verify:

• Disclosure appears on first interaction
• Human escalation option is visible and functional
• Periodic reminders trigger as configured
• Disclosure events are logged
• Escalation transfers to correct queue
• Compliance can generate disclosure reports

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