Books and Records: Rapid Fire
Chapters in this video
- 0:00 The umbrella rule and the dual-offense trap
- 1:34 Dual sign-off, name changes, and manual signatures
- 2:45 WORM, access undertakings, DEA, and independent cloud access
- 3:52 Form BDW is a custody event, not a destruction event
- 4:48 The 6-4-3 retention ladder and Riley's email mistake
- 7:02 Nonresident broker-dealer 14-day production rule
- 7:36 Taping rule thresholds and the absolute-count trap
- 9:37 Rapid-fire exam recap
What this video covers
- Why a format failure under SEC rules creates a standalone FINRA offense through the umbrella books-and-records rule
- How the recordmaking rule differs from the records-retention rule, and which governs dual sign-off versus which governs WORM storage format
- When discretionary accounts require a dated manual signature rather than electronic approval
- Why the 6-4-3 baseball retention ladder means customer info at 6 years, complaints at 4 years, and authorizations at 3 years, with each clock starting at a different trigger event
- How Form BDW creates a custody event requiring pre-filing affirmative custodian consent, not a destruction event
- Why the taping rule middle band of 10-19 registered persons triggers at an absolute count of 4, not a percentage
- When the longer retention period controls between FINRA and SEC rules, and why the SEC 3-year communications floor tripped Riley at 2.5 years
Read the full lesson, free
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