Custodian of Books and Records (Post-Withdrawal)
Chapters in this video
- 0:00 Filing Form BDW and why withdrawal is blocked without a custodian
- 1:14 The two exclusive categories of eligible custodians
- 3:21 Pre-filing affirmative consent and informed consent rules
- 4:39 Permitted format conversion versus prohibited record cleanup
- 6:28 Inherited retention clock and the non-reset rule
- 7:02 Rapid-fire exam recap
What this video covers
- Why a Form BDW (Uniform Request for Broker-Dealer Withdrawal) filing is incomplete and will be blocked without a designated records custodian
- The two exclusive categories of eligible custodians: a person associated with the member at filing, or another FINRA member
- Why a former associated person, a non-FINRA-member law firm, a non-member clearing firm, or any other outside entity cannot serve as custodian
- The requirement that custodian consent must be affirmative, informed, and documented on a signed Custodian Consent Form before Form BDW is filed
- Why filing Form BDW first and obtaining consent afterward is non-compliant and blocks withdrawal
- Which format conversions are permitted (scanning paper to electronic, migrating electronic media) versus what is prohibited (omitting, editing, summarizing, or weeding out records during conversion)
- Why the retention clock does not reset upon transfer, and how the custodian inherits only the remaining years of the original retention period
Read the full lesson, free
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