A short briefing that explains how AI tools work, where your data goes, why a standard
Claude subscription is fine for ACL-licensed advisory work, and how to start safely —
including a free MFAA-aligned policy template you can adapt today.
No pitch, no packages. Just the guidance.
A "Large Language Model" — Claude, ChatGPT, Copilot, Gemini — is essentially a sophisticated
autocomplete that has read most of the public internet. You give it text. It generates text back.
That's the whole trick. The magic is in how good it has become at it.
Three things to internalise:
It runs in a datacentre, not on your laptop. The actual AI lives on
specialised chips (GPUs) in a building somewhere. Where that building is matters a lot.
It doesn't remember you. Every chat starts fresh. Some products bolt
memory features on top, but the underlying model is amnesiac.
It can be confidently wrong. "Hallucination" — the model fabricating
names, numbers, regulations. Always verify before relying on outputs.
Bottom line
An AI tool is a service you connect to, not software you install. Choosing one is a
procurement decision (provider, location, terms) more than a technical one.
Section 02
Where your data goes
When you type something into an AI chat box, your text takes a journey. Three stages, each
with different implications:
// the three states data passes through
What this means for Coltbridge
The country the datacentre sits in is the country whose laws govern your data while it's being
processed. For an ACL-licensed advisory firm doing mid-market debt work:
Not catastrophic, but not zero. Your clients may have
contractual or commercial expectations about confidentiality that don't easily fit
"we sent your financials to a US AI service."
The MFAA AI guidance puts privacy front and centre. Privacy of client
data is one of the five principles for safe AI use (see Section 3).
Worth being deliberate about. Choose an option where you can answer
"where does our data go" with a clear, defensible sentence.
Section 03
MFAA principles & free policy
The MFAA's discussion paper Embracing the future: Towards the safe and ethical use of AI
for the mortgage and finance broking industry identifies five principles for safe AI use
in finance. They're sensible, and they apply equally well to debt advisory work even though
the paper was written for retail brokers.
Privacy
Be deliberate about what data goes where. Define what classes of information
can/can't go to AI tools, and stick to it. Approved-tools list, no off-list usage.
Bias & Accuracy
Verify outputs. AI fabricates confidently. Pay extra attention to financial
figures, lender names, regulatory references, dates, and any specific commitment language.
Accountability
Humans own outputs. "The AI did it" is not a defence. Designate an AI lead
with policy ownership. Treat AI-assisted work the same way you'd treat work from a junior —
reviewed and signed off before it leaves the firm.
Transparency
Be clear with clients about how AI is used. A written disclosure stance —
when AI is mentioned, when it isn't, how to answer if a client asks. Internal logging for
management review.
Human Element
AI augments judgement, never replaces it. AI as a drafting and research
assistant only. No autonomous client communication. No advice without human review.
The free policy template
We've drafted an MFAA-aligned acceptable-use policy template you can adapt for Coltbridge.
It's about three pages, structured around the five principles above, with concrete rules for
each. Replace the bracketed fields with your specifics — firm name, AI lead, approved tools,
review cadence — and you have a defensible governance document.
Download · Markdown
AI Acceptable Use Policy Template
8 sections covering privacy rules, accountability, approved tools list, AI lead role, incident handling, and annual review cadence. Adapt freely.
Aligned to MFAA principles. Not a substitute for legal advice — review with your compliance
adviser before formally adopting it.
Section 04
Yes, you can use Claude Pro
The single most common question we get from firms in your position is some version of:
"Can we actually use a normal Claude subscription, or do we need something fancier to be
compliant?" Short answer: yes, you can. Long answer: with the right
habits, a standard Claude Pro, Team, or Max subscription is genuinely fine for ACL-licensed
debt advisory work. Here's why.
The legal mechanism that makes it work
Three facts in combination:
ACL licensees aren't bound by APRA-style data residency rules. Those
rules apply to ADIs, RSEs, and other APRA-regulated entities. ASIC's general obligations
for credit licensees (RG 104) and dispute resolution requirements (RG 271) don't prohibit
offshore AI services.
De-identified data isn't "personal information" under the Privacy Act.
That means APP 8 — the cross-border disclosure principle that would otherwise apply when
you send personal information overseas — isn't triggered. This is the legal hinge the
whole approach turns on.
Anthropic's commercial terms explicitly state they don't train on customer data.
So inputs you provide to Pro, Team, or Max don't propagate into the model. Your prompts
live in their infrastructure, used to generate your response, then bounded by their
retention policy.
Combine those, and the picture is: a Claude subscription with sensible obfuscation habits
keeps your client data outside the categories that trigger the rules people worry about. Not
because of clever workarounds, but because that's how the rules are designed.
The honest read
Subscription Claude with the right habits is the right starting point for the vast majority
of firms in your position. You don't need onshore Bedrock to be safe. You need
a written policy, an AI lead, and the discipline to obfuscate before pasting. That combination
sits comfortably inside MFAA principles, the Privacy Act, and your ACL obligations.
What "obfuscation" actually means in practice
We're not talking about cryptographic anonymisation or formal de-identification protocols.
We're talking about a habit: before pasting, swap identifying details for placeholders.
It takes ten seconds and it changes the legal character of the data.
DoReplace client names with generic placeholders. "Client A",
"Lender B", "the Borrower." Round identifying figures slightly — "$42.7m"
becomes "~$40m" if the precise number isn't material to the task.
DoUse it confidently for structure, drafting, review, analysis,
and iteration — anywhere the client identity isn't essential to the task. Most
Coltbridge work falls into this category.
DoKeep prompts portfolio-generic. "Mid-market property
refinance, $40m, three-year term, mining-services tenant" instead of "Smith Family Trust,
12 Acacia Street, MineCo as tenant."
DoUse the firm's paid subscription, not personal
accounts. The firm's account has commercial data terms; personal Free/Plus accounts have
consumer data terms.
Don'tPaste full identity documents, bank account numbers, TFNs,
passport details, or anything where a leak would matter even with names removed.
Some data should never go to AI tools regardless.
Don'tCombine client name and financial position in the
same prompt. The combination is what makes information identifying. Either name or numbers
— not both.
Don'tUse free or personal accounts for work. Different
data terms apply, and personal accounts don't carry your firm's data agreements with the
vendor.
Don'tTreat obfuscation as a licence to skip the policy.
The habit only works if everyone does it consistently — that's what the acceptable-use
policy in Section 3 is for.
What about the M365 connector?
The Claude M365 connector (covered in Section 5) reads your SharePoint and Outlook directly.
That data is identifying by definition — there's no obfuscation step. This is fine
because the connector is permission-mirrored: Claude can only see what each user can already
see, and the same paid commercial terms apply. The data flows under your firm's commercial
agreement with Anthropic, not under the looser personal-account terms.
It does mean the connector represents a stronger commitment than copy-paste with obfuscation —
so it's worth being deliberate about turning it on, and worth covering it explicitly in your
acceptable-use policy.
A note on legal advice
None of this is legal advice. We're not lawyers. What we can tell you is that this is the
pattern we see consistently across Australian financial advisory firms using AI well — and
it's the pattern the MFAA paper points toward, even if it doesn't say it as plainly as we
have here.
Confirm with your compliance adviser before formally adopting it. But your
instinct that you can probably just use a Claude subscription is correct. You don't need our
permission, you don't need expensive infrastructure, and you don't need to wait. The
downloadable policy template in Section 3 codifies exactly this approach — fill it in, get it
signed off, and you're moving.
Section 05
The four real options
For a firm of your shape, four pathways are worth understanding. Everything else is a flavour
of one of these.
Claude Direct
Best-in-class for drafting
Cheapest to start
M365 connector reads SharePoint, OneDrive, Outlook, Teams
Inference happens in the US
Connector is read-only — can't write back into M365
ChatGPT Enterprise
Polished out-of-box experience
AU data-at-rest available
Inference still happens in US
More expensive per seat
You said you want Claude
M365 Copilot
Lives inside Word, Excel, Outlook
Can write/edit documents directly
Lowest learning curve for office work
Less flexible than chat tools
Most "read M365 data" use cases now covered by the Claude connector
Bedrock Claude (Sydney)
Inference stays in Australia
Strongest residency story
Cheapest per-token at scale
No built-in chat UI — needs setup
No M365 connector — would need custom integration
The M365 connector — what just changed
In late 2025 Anthropic released a Microsoft 365 connector for Claude that materially changes
the office-integration picture. Available on all Claude plans — Pro and Team
included — and once enabled, Claude can:
Search and read your SharePoint sites and document libraries
Search and read files in OneDrive
Read and search Outlook emails (incl. archived threads)
Read Teams chat messages and channel discussions
Read Calendar events and online-meeting transcripts
For Coltbridge, this is the workflow gap-closer. An advisor can ask:
"Find the IM template we used for [Client X] last quarter and adapt it for [Client Y]
using their briefing notes in SharePoint."
"Summarise the email thread with [Lender Y] about the refinancing — what did we agree
on rate, fees, and covenants?"
"Pull the deal notes from our last three meetings with [Client Z] and flag anything
still outstanding."
Important caveats
Read-only. Claude can search and analyse your M365 data but can't modify or
send anything from it.
Permission-mirrored. Claude only sees what the user can already see — no
access bypass.
Doesn't change residency. M365 data flows into Claude's standard US-based
inference.
Setup is light. One-time consent from your Entra Global Admin (~5 min),
then each user authorises individually.
Section 06
What it actually costs
Two ways to pay for AI: subscription (flat per user per month) or
pay-per-use (pennies per token). For a 5-person firm starting out,
subscription wins on simplicity and predictability.
Subscription pricing (April 2026)
Plan
Per user / month
Notes
Claude Pro
~$30 AUD
Single user, ideal for trial phase
Claude Team
~$45 AUD
5-seat minimum, shared workspace, M365 connector included
M365 Copilot
~$45 AUD
Add-on to existing M365 licence
ChatGPT Team
~$40 AUD
Comparable to Claude Team
Real Coltbridge tasks (pay-per-use, Claude Sonnet 4.6)
Drafting an Information Memorandum section: ~$0.08 per draft
Reviewing a 50-page term sheet: ~$0.15 per review
30-minute iteration session on a financing structure: ~$0.60
One advisor heavy day: ~$3–5
The takeaway
If all 5 of you used AI heavily every working day of the month, raw API costs would be
$200–400 AUD/month total for the firm. The compute is cheap. What you pay
extra for in subscriptions is the polished interface and predictable flat rate.
For 5 people exploring AI, subscription wins. Claude Team at ~$230/month
total is paying for predictability, polish, and account management. You won't hit the
break-even point with API tokens until you're doing 30+ heavy sessions per user per workday
— way beyond exploration phase.
Section 07
A simple way to start
You can run this entire path yourselves over three to four weeks. Five steps. Total commitment
to first decision point: about $30 AUD.
Step 01
Pick an AI lead. One person who's curious about new tools, willing to learn,
and respected enough that the team will listen to their experience. They'll own the rollout
and become the firm's go-to for AI questions.
Step 02
Adapt the policy template we provided. Spend 30–60 minutes with the AI lead
and one other person — fill in the bracketed fields, agree on what data classes can/can't go
to AI tools, agree on the review cadence. Don't skip this.
Step 03
Trial Claude Pro — $30/month, one user, two weeks. The AI lead uses it for
~30 minutes per day on real but sanitised Coltbridge work. Drafting templates, reviewing
public-info documents, summarising long threads. Avoid client-identifying material until
you've upgraded to Claude Team.
Step 04
Show and tell. The AI lead presents 3–5 concrete examples to the team —
what worked, what didn't, what surprised them. Honest tone. The point is for everyone to
form a realistic mental model, not to over-sell.
Step 05
Decide. Roll out Claude Team for all five (~$230/month) and turn on the
M365 connector. Or stay on a single Pro account. Or pause if it's not landing. If you
upgrade, the AI lead becomes the ongoing point person — answering questions, sharing
prompts that work, flagging compliance questions.
That's the whole path. If you'd like a hand with any of it, see Section 8.
But none of this requires us — it requires one curious person, a couple of conversations,
and a free policy document.
Section 08
Common pitfalls to avoid
Six ways AI gets used badly in finance firms. Avoiding these is most of the battle.
Trusting numbers. AI fabricates figures with extreme confidence. Verify
every financial value, percentage, date, and citation before output leaves the firm. This
is the single highest-risk failure mode in advisory work.
Pasting client-identifying data into free tools. ChatGPT free, Gemini free,
Copilot free — these have different data handling than the paid tiers, and personal accounts
don't carry your firm's data agreements. If a tool isn't on your approved-tools list, treat
it as the public internet.
Letting AI hit "send." Drafting with AI is fine. Iterating with AI is
fine. But the moment a piece of content leaves the firm, a human must have reviewed and
approved it. AI-drafted client emails that go out unchecked is how reputational damage starts.
Believing it understands your firm. AI is great at general knowledge,
average at specifics. It will get lender names, current product features, regulatory
references, and Australia-specific details wrong. Treat it as a knowledgeable generalist,
not a Coltbridge expert.
Skipping the policy. "We'll write the AI policy later" tends to mean
"we'll write the AI policy after the incident." The downloadable template above is
deliberately simple — a few hours of work and you're protected.
Treating it as autonomous. AI is a junior colleague who needs supervision.
It's not a replacement for advisor judgement. Workflows that try to remove the human entirely
fail in ways that workflows with humans-in-the-loop don't.
The pattern underneath
Most AI failures in finance firms come from treating the tool as more capable than it is
— assuming it knows your specifics, trusting its outputs without verification, removing human
review steps to save time. The firms that use AI well treat it as a thoughtful but unreliable
assistant. Useful, but never authoritative.
Section 09
If you want hands-on help
Most firms can run the path above on their own. The five steps are deliberately simple, the
policy template covers the governance basics, and Claude Team's setup is genuinely a
self-service experience.
That said — if you find a workflow you'd like to automate and can't quite get there yourselves,
we're available ad-hoc at $200/hr + GST. No retainers, no minimums, no
ongoing commitments.
Common things people ask us for
Prompt engineering for specific recurring tasks. A Coltbridge-specific
prompt for IM drafting, term sheet review, or lender comms can take a generic chat session
and turn it into a repeatable, reliable workflow. Typically 2–4 hours per workflow.
Workflow design. Turning "wouldn't it be great if AI could..." into
something that actually works — including identifying when AI shouldn't be used.
Usually a 2–3 hour scoping session followed by build work.
Tool selection & setup when something more advanced than Claude Team
is genuinely needed — onshore Bedrock deployment, custom MCP integrations, agent workflows.
Quoted on a per-engagement basis after a free scoping conversation.
Compliance review. Independent assessment of how you're using AI against
MFAA principles. Useful before client audits or when onboarding new staff. Typically 4–6
hours.
Training. A 90-minute team session on practical AI use, MFAA principles
in practice, and verification habits. $400 + GST for a session of up to 10 people.
How engagements work
Free 45-minute scoping conversation to understand what you need.
Written quote with a specific deliverable and a fixed-hour estimate.
Work begins after you say yes. Invoiced on completion.
If we hit the hour limit and aren't done, we discuss before continuing — never a
surprise overrun.
Engagements are project-based. No ongoing retainers. Re-engage when you want.
A note on incentives
This briefing exists because we'd rather you understand AI well and use it confidently
yourselves than be dependent on us. We make money when you ask us to do something hard.
We don't make money on the basics — and the basics, including everything in this document,
are free.
Questions, or want to think it through?
45-minute scoping conversation, free. Bring questions, situations you're not sure about, or a workflow you'd like to discuss.