General Books-and-Records Requirements (FINRA-SEC Bridge)
Chapters in this video
- 0:00 The kitchen rule: three sources of authority
- 1:27 How the umbrella rule creates FINRA jurisdiction
- 2:00 The 6-year default floor and account closure trigger
- 3:33 The 4-year and 3-year exceptions
- 4:57 SEC electronic format mandates: WORM and audit trail
- 6:36 The longer period controls rule
- 7:15 Rapid-fire exam recap
What this video covers
- The three sources of recordkeeping authority (Securities Exchange Act of 1934, SEC rules, and FINRA rules) and how the umbrella rule bridges them
- Why the FINRA umbrella violation is a standalone offense separate from any underlying SEC charge, even for the same format failure
- The 6-year default retention floor, including the critical distinction between account-related records (6 years after account closure) and non-account records (6 years after the record is made)
- The major exceptions: 4 years for written customer complaints and 3 years for communications, superseded compliance manuals, and expired negotiable-instrument authorizations
- The two SEC-acceptable electronic storage formats: Write Once, Read Many (WORM) and the audit trail alternative
- Why format compliance is totally separate from content compliance under the umbrella rule
- The "longer period controls" rule when SEA and FINRA retention periods conflict for the same record
Read the full lesson, free
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