Sec Rec 17a4
SEC Regulation 17a4(f) SEC Background The Securities and Exchange Act of 1934 has provisions that demand exchange members, brokers and dealers to uphold and preserve records of their business, including transactions, trade confirmations, communications (including interoffice memoranda), and written agreements. With the arrival of computer technology, in addition to word processing software, spreadsheet and financial software and email software, as well as hardware devices and media to store electronic information, the SEC has updated these rules to include provisions for storage of records on electronic storage media. ... 17 a-4(f), which outlines SEC regulations regarding management of and access to electronic records. The SEC requires firms to ˇ§preserve for a period of three years, and or preserve in an accessible place for two years, electronic communications relating to the business of the firm, including inter-office memoranda and communication.ˇ¨ (SEC Press Release, 12/02) Failure to comply threatens a firm to substantial risk and penalties. ˇ§SEC, NYSE, NASD fined five firms a total of 8. ... ˇ¨ (SEC Press Release, 12/02) Although companies must meet many requirements that are part of Rule 17a-4(f), those of specific interest & related to Document Management include: „h Preserve the records exclusively in a non-rewriteable, non-erasable format. ... The universality and utility of email as a communication medium is both a benefit and a possible problem for financial companies regulated by the SEC. ... Record-keeping insufficiencies are among the most common reasons that the SEC Office of Compliance Inspections and Examinations refers cases to the Office of Enforcement or to Self-Regulating Organizations (SROs) for investigation. In 1999, the Office of Compliance referred nearly 30% of the 681 inspections it performed to either Enforcement of SROs for further investigation (SEC annual report ˇV 1999). ... EMC delivers a cost effective, online SEC compliant e-mail archive solution that completely automates the storage management process and obviates the need for expensive resource and budgetary commitments. ... The EMC content management solution offers brokers/dealers: „h Ability to meet SEC 17 a-4 requirements „h Lower five year TCO than optical/tape „h Pre-qualified 17 a-4 application partners „h Complete automated networked storage solution integration A Company must maintain solid storage management, especially with respect to electronic records.