Identify the business activity
Choose a communication or report and confirm who is responsible for its classification.
FINRA · Broker-dealer file exchange
FINRA recordkeeping and broker-dealer file exchange
When a broker-dealer releases a client report, the delivery record and retained business record may answer different questions. Ask the supervision team what it must retrieve later.
Assign supervisory review
Record who approves release and where the approval can be found.
Test retrieval
Ask a colleague to find the retained record and connect it to the relevant transfer.
Trusted with valuable business data
Trace a report from approval to retention
Document the owner, recipient and archive destination. Test retrieval through the firm’s approved process before relying on the workflow.
Identify the record.
Ask the supervisory owner which business activity and record the proposed communication represents.
Control distribution.
Identify the approved reviewer and keep the release conditions with the business record.
Preserve in the right system.
Confirm the archive destination and the person responsible for applying the retention procedure.
Retrieve with context.
Ask a second reviewer to locate the record and explain its relationship to the transfer.
Separate the delivery question
from the retention decision.
What happened to the file?
Use delivery activity to investigate whether the intended recipient accessed the package.
Explore exchange records ↗Can the record be preserved and produced?
Ask the records owner to demonstrate retrieval using the designated recordkeeping system.
A delivery log alone does not establish a compliant electronic recordkeeping system.
Try a retrieval request before you need one.
Choose a synthetic client-document exchange and ask a colleague who did not send it to reconstruct the record. This exposes gaps between a successful delivery and a record that another person can locate, understand and produce.
Start with a business question
Choose a realistic request, such as finding the issue sent to a client for a particular reporting period.
Find the retained version
Use the archive to identify the approved version covered by that request.
Reconstruct the context
Connect the retained file to the approval, recipient and activity it documents.
Document the gaps
Assign each missing item to an owner and repeat the retrieval test once the issue is resolved.
Watch the joins between systems.
The point where a file moves from delivery into preservation deserves explicit ownership. Ask your compliance and operations teams to describe the handover, including what happens when the normal process fails.
- A delivery record without its document
- Establish how exchange activity is associated with the retained file. Matching only on a filename may become ambiguous when files are renamed or resent.
- A document without its correspondence
- Determine whether instructions, approvals or related messages form part of the record your team needs to preserve. Define where that context is kept.
- A closed account with unfinished records
- Include staff departures and role changes in the exercise. Confirm who can retrieve relevant records after the original sender no longer has access.
Prepare for the conversation
- A synthetic document
- Use an example that reflects a real business-record category.
- Your retention decision
- Identify the system intended to preserve the official record.
- A retrieval question
- Bring a request your supervisory or operations team would need to answer.
Make retrieval part of the demonstration.
Bring a synthetic client-document workflow. Explore the exchange with MX, then confirm where the official record and any required supporting evidence will be retained.
Discuss your record handoverQuestions for
your review.
Is MX a FINRA-approved archive?
This page makes no claim of FINRA approval or compliant archival capability. Evaluate the exact service and recordkeeping environment before relying on them.
Does every record have the same retention period?
No. Identify the record category and the applicable rule. Do not apply a single retention period to every file exchanged by a broker-dealer.
Does link expiry delete a retained business record?
Do not equate the two. Access availability and required record retention are separate controls. Establish which copies exist and which system manages preservation.
What should compliance review before rollout?
The business-record classification, approved channels, supervisory process, applicable retention requirements and retrieval procedure. Include the role of each provider and any remaining gaps.