Records to Be Preserved

What this video covers

• When the three-year retention clock on compliance, supervisory, and procedures manuals actually starts (superseded, not created), and why a 12-year-old active manual has zero days elapsed
• Why every version of a manual is preserved separately, and why firms cannot keep only the latest version
• The two permitted electronic storage standards, Write Once, Read Many (WORM) and the audit-trail alternative, and why they remain equal valid choices after recent amendments
• What the access undertaking requires, who may file it (third party or executive officer), and where it is filed (Designated Examining Authority (DEA), which is FINRA for most broker-dealers)
• Why prior notification to the DEA before adopting electronic storage is no longer required
• What independent access means for cloud storage, and why vendor-controlled portals fail the test
• Why retention obligations continue after a firm ceases business, and what promptly furnishing records to the Securities and Exchange Commission (SEC) entails