Electronic Recordkeeping and Where Records Must Live

What this video covers

• The two acceptable electronic preservation methods: non-rewriteable, non-erasable (WORM) format versus the time-stamped audit-trail alternative, and which one carries the extra standalone audit-system burden
• Why the audit-trail alternative must be able to recreate the original record after modification or deletion, and why an ordinary activity log does not satisfy this requirement
• The two built-in duties that apply to every electronic recordkeeping system: automatic verification of completeness and accuracy, and always-on capability to download in both human-readable and reasonably usable electronic formats
• The three promises in the undertaking: furnish promptly, download in both formats if the firm fails, and provide access with reasonable notice after firm failure
• Who may sign the undertaking: either a designated executive officer with system access or a designated third party, with exactly one signature required
• Why appointing up to two designated officers and three designated specialists as backups never relieves the designated executive officer of the underlying obligation
• The two-year office location rule for blotters, order memoranda, customer account records, communications, and compliance manuals, plus the home-office exception conditions