FRB opens its AI policy playbook to law firms and SMBs

Falcon Rappaport & Berkman has published its internal generative AI policy and related templates on GitHub for free public use, aiming to help law firms and small to midsize businesses build stronger AI governance. The release includes a law firm policy, a general business template, a customization guide, and a browser-based builder at More information.

Why it matters: - Falcon Rappaport & Berkman is putting a usable AI governance framework in the hands of smaller firms and businesses that do not have the budget or staff to build one from scratch. - The release targets practical risk areas that many policies miss, including autonomous AI agents, meeting transcription tools, and AI use in hiring decisions. - The templates are designed to help organizations raise their baseline controls before courts, regulators, insurers, and business counterparties demand stronger oversight.

What happened: - FRB published its internal generative AI policy and related templates on GitHub under a CC0 public-domain dedication. - The package includes two full templates: one for law firms and one for general business use. - The release also includes FRB’s own adopted policy, a customization guide, and an AI skill that can interview users and draft or compare a policy. - A guided web version at More information lets law firms and SMBs create a starter policy in about three minutes. - The guided site uses a 1990s GeoCities-style design as a deliberate throwback.

The details: - The templates address approved AI tools, mandatory verification of AI output, confidentiality, data security, AI notetakers, meeting transcription, agentic AI, AI in employment decisions, and enforcement. - The policy package is available for any organization to adapt without asking FRB for permission. - The templates are based on the policy FRB attorneys wrote, debated, and adopted for the firm’s own multi-state practice. - The customization guide walks users through tailoring a policy to their tools, jurisdictions, and risk profile. - The guide also points users toward broader governance frameworks such as the NIST AI Risk Management Framework. - FRB says the templates are educational resources and not legal advice. - FRB encourages organizations to have any finished policy reviewed by their own counsel. - Organizations can contact FRB at ai@frblaw.com for policy review or help building a broader governance program. - Press inquiries should go to pr@frblaw.com. - The policies were principally authored by Moish Peltz, Christopher D. Warren, Allen Abraham, Simon Uritsky, Elizabeth Schlissel, and Alexander Migliorini, with other members of the FRB AI Committee.

Between the lines: - The move reflects a broader shift from informal AI caution to formal governance, especially in professional services where client confidentiality and output reliability are central. - FRB is positioning open source as the answer to a resource gap, arguing that small firms can pool expertise instead of trying to outspend larger competitors. - The release also signals that AI policy is becoming a standard operating document, not a one-time compliance checkbox.

What's next: - FRB wants firms and businesses to adapt the templates, then build them into a larger governance program. - The firm is inviting collaboration and expects users to refine the templates for their own tools and jurisdictions. - Organizations that want hands-on help can ask FRB attorneys to review their tailored policy or support implementation. - The public-facing policy effort may also serve as a model for other firms looking to share compliance infrastructure instead of keeping it proprietary.