What you would have to build internally in 24-36 months.

● enforced · ◐ available · — not applicable

• Gate 1 Producer + agency license per state. Sage Voice routes only to states where the tenant has declared producer + agency license. Calls that would bind outside licensed states are rejected at the API. NAIC Producer Licensing Model Act #218; state Insurance Code.
• Gate 2 Carrier appointment per (product × state). The recommendation pipeline reads the tenant's carrier-appointment matrix and refuses to recommend a carrier the tenant is not appointed for in the consumer's state of solicitation. Carrier producer agreement; state appointment filings.
• Gate 3 NAIC Best Interest documentation. Model #275 § 6.A.1 consumer-profile fields captured before any recommendation. Validation blocks the recommendation event if fields are missing. NAIC Suitability in Annuity Transactions Model Regulation #275; NY 11 NYCRR 224 (Reg 187); IA 191—15.69; FL § 627.4554.
• Gate 4 AI disclosure delivery + acknowledgement. Federal NAIC Model Bulletin baseline + state add-ons (CO, NY, CA, UT) resolved per call. Disclosure text + acknowledgement timestamp persisted in audit log. NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 2023); CO C.R.S. § 10-3-1104.9 + 3 CCR 702-10 Reg 10-1-1; NY DFS Insurance Circular Letter No. 7 (2024); CA SB 1001; UT S.B. 149 (2024).
• Gate 5 Replacement disclosure (life only). When the consumer reports existing life insurance, the assistant captures each policy + proposed action + reason and reads the state-specific replacement notice if proposed action is replace or surrender. NAIC Life Insurance and Annuities Replacement Model Regulation #613.
• Gate 6 MIB + Rx consent (life only). Scripted authorization captured before any MIB or Rx pull. Audit log records consent + timestamp. FCRA 15 USC § 1681; MIB Group authorization standards.
• Gate 7 TCPA + two-party recording consent. Pre-call check verifies prior express written consent for outbound AI voice (FCC 23-107 one-to-one consent). Recording-consent script triggered in two-party-consent states. TCPA 47 USC § 227; 47 CFR § 64.1200(a); FCC 23-107 (Dec 2023); state wiretap statutes.
• Gate 8 Anti-rebating. Commission disclosure script delivered before any specific carrier recommendation; tenants own their compensation tier structure. CA Ins Code § 750; NY Ins Law § 2324; FL § 626.572.
• Gate 9 State producer-compensation disclosure. Where state requires (e.g., NY 11 NYCRR 30, IL ICC), additional disclosure script injected into the system prompt. NY 11 NYCRR 30; state-specific producer-compensation rules.
• Gate 10 Carrier supervisory framework. Every audit event is attributed to a supervisory chain — writing-agency principal → producer of record → assistant. Carrier supervisory provisions in producer agreement.
• Gate 11 Record retention (5–7 yr, state-dependent). Audit log entries immutable. Transcripts encrypted at rest in R2 with per-tenant key derivation. Lifecycle policy configured per tenant's state. State Insurance Code recordkeeping; carrier supervisory expectations; NAIC Market Conduct Examination standards.

• BAA chain — Sage Voice + downstream providers. Tenant signs BAA with Sage Voice. Sage Voice maintains BAAs with downstream providers (Retell, Vapi, OpenAI, Anthropic, ElevenLabs, Cloudflare). Healthcare-vertical calls refuse to route to providers outside the tenant's declared BAA list. 45 CFR § 164.504(e).
• PHI Safe Harbor redaction on audit entries. All 18 identifier categories handled by a conservative regex pass before any audit entry is persisted. Healthcare-vertical entries with redacted=false are rejected at the Durable Object. 45 CFR § 164.514(b)(2).
• Minimum necessary standard. Prompt library scopes intake to general chief complaint and duration only; diagnosis codes, lab results, imaging, and psychotherapy notes are excluded. 45 CFR § 164.502(b).
• Notice of Privacy Practices delivery. Scripted at call start with text/email delivery confirmation captured. 45 CFR § 164.520.
• HIPAA authorization for non-treatment disclosures. Structured capture aligned to § 164.508 elements. 45 CFR § 164.508.
• Audit controls. Immutable hash-chained audit log with HMAC signing per entry; integrity verifiable via GET /api/v1/audit/verify. 45 CFR § 164.312(b).
• Six-year retention. R2 lifecycle policy + Durable Object retention configured for 6+ years by default. 45 CFR § 164.530(j).
• California AB 3030. AI disclosure scripted on calls placed to or from California numbers. Cal. Health & Safety Code § 1339.75.

• CIP / KYC capture. Structured customer-identification fields persisted in the tenant's KYC store with audit-log linkage. SSN captured via DTMF, never voice. 31 CFR § 1020.220 (banks); § 1023.220 (broker-dealers); FINRA Rule 2090.
• OFAC screening. Pre-funding screening hook with silent escalation on hit (the assistant does not reveal screening outcome to the customer). 31 CFR Part 501.
• FCRA / ECOA notice. Scripted before any credit pull; acknowledgement captured in audit log. 15 USC § 1681; 12 CFR Part 1002 (Reg B).
• Reg E disclosure summary. Delivered on EFT enrollment; full Reg E disclosures mailed/emailed via tenant's downstream pipeline. 12 CFR Part 1005.
• Reg BI + Form CRS. Broker-dealer suitability capture; Form CRS link delivery and receipt confirmation in audit log. 17 CFR § 240.15l-1; § 240.17a-14.
• GLBA Privacy. Privacy notice delivery confirmable per tenant's GLBA program. 15 USC § 6801; 16 CFR Part 313 (Reg P).
• PCI DSS scope-out via DTMF. Cardholder data never enters Worker memory in plaintext; DTMF channel is P2PE. PCI DSS v4.0.

• Section 508 accessibility. TTY/relay friendly; transcripts available; opt-out to human channel always one phrase away. 29 USC § 794d.
• Privacy Act of 1974. For federal agency tenants: SORN reference + routine-use disclosure in script. 5 USC § 552a.
• State records-act retention. Configurable retention per state — CA Public Records Act (Gov. Code § 7920 et seq.) 5y, TX Public Information Act 5y, CO Open Records Act 3y, NY FOIL 6y.
• State privacy law overlays. CA CPRA, CO CPA, VA VCDPA, CT CTDPA, UT UCPA, TX DPSA — voice recording = personal information, right to delete supported for non-statutorily-retained records.
• NIST SP 800-53 Rev 5 / FedRAMP path. Tenant ATO process supported via SSP boilerplate + control-mapping artifacts. NIST SP 800-53 Rev 5.

Every Sage Voice call produces an immutable audit log: per-tenant Cloudflare Durable Object, SQLite-backed, append-only. Each entry is hash-chained to the previous (SHA-256 of canonical JSON) and HMAC-signed with a per-tenant signing key. Chain integrity is verifiable with a single API call. Compatible with OpenTimestamps anchoring for external cryptographic timestamp.

Healthcare entries pass through HIPAA Safe Harbor redaction before persistence. Healthcare entries with redacted=false are rejected at the Durable Object layer — there is no path to a healthcare audit entry containing PHI.

Architectural note: the audit log is the system of record; the transcript R2 store is a downstream cache. If the transcript bucket is lost, the audit chain remains intact and discoverable.

• Make legal compliance decisions for the tenant. Tenants engage regulatory counsel.
• Sign the BAA on the tenant's behalf with downstream providers.
• Promise that delivery of a disclosure equals affirmative defense. The audit log is necessary but not sufficient.
• Bypass the licensed-producer / licensed-clinician / licensed-banker handoff. Every recommendation is human-reviewed.

Sage Voice provides compliance infrastructure. Tenants are responsible for engaging insurance regulatory counsel (Stradley Ronon, Locke Lord, Faegre Drinker, Foley & Lardner, McDermott Will & Emery), signing BAAs for healthcare, completing SOC 2 audits where applicable, and maintaining the substantive compliance program.