Books, Records and Regulation FD: Rapid Fire

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What this video covers

  • The Financial Industry Regulatory Authority (FINRA) default retention period for records with no stated period, and why six years is your guess-of-last-resort
  • The two different six-year triggers for account cards versus customer account information: account closing versus each update, plus the accessibility requirement that attaches to the latter
  • The unique four-year retention for written customer complaints, and why it breaks the standard three-year or six-year mold
  • Order memoranda rules: three years from creation, first two easily accessible, kept whether executed or not, and the discretionary-designation requirement
  • The two valid electronic preservation routes, and why only the Write Once, Read Many (WORM) format requires a separate audit system
  • The three traps that overlap with retention: making versus preserving, ceasing business not shortening the clock, and the longer period prevailing when the Bank Secrecy Act overlaps
  • Regulation FD binding the issuer not the broker-dealer, the simultaneous-versus-prompt disclosure distinction based on intent, and the specific 24-hour or next-trading-day deadline for non-intentional leaks

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