Select the record
Identify the business activity, record owner and version covered by the request.
SEC Rule 17a-4 · Electronic recordkeeping
SEC Rule 17a-4 and electronic record retrieval
A broker-dealer may need to produce the report a client received months ago. Test whether the records team can retrieve the retained version, connect it to the release and explain its history.
Confirm the preservation method
Ask the records owner how the approved system preserves the record and associated evidence.
Run a production test
Give a reviewer the request and check what they can produce without help from the original sender.
Assess the preservation approach
Work with the records team to evaluate the applicable electronic recordkeeping requirements and the system used to meet them.
WORM preservation
Evaluate how the chosen recordkeeping system prevents rewriting or erasing retained records for the applicable period.
Ask: What configuration, scope and operational evidence support the preservation claim?
Audit-trail alternative
Evaluate how the system preserves a complete history and permits recreation of an original record after modification or deletion.
Ask: Can the system demonstrate that outcome for the actual record types and changes in your workflow?
Retrieve a representative report
Start with a client, date and report reference. Document which version was retrieved, what history accompanies it and any gaps.
- 01
Identify the retained record.
Confirm its type, owner and applicable retention requirements. Include supporting information needed to understand it.
- 02
Exercise the preservation route.
Ask the recordkeeping provider to demonstrate the relevant controls, including how modifications or deletion attempts are handled.
- 03
Request a complete output.
Check that the record and required supporting information can be located and produced in the appropriate forms.
Connect delivery to the retained record
Keep the release reference with the business record so a later reviewer can trace what the client was sent.
Business workflow
Prepare the information.
File exchange
Deliver to the intended party.
Recordkeeping system
Preserve and produce.
Confirm any integration, preservation and retrieval requirements before implementation.
Bring the retention requirement.
Map the delivery step.
Use a sample broker-dealer workflow to explore the exchange with MX. Review the preservation system, evidence and applicable undertakings with your compliance team.
Review your record workflowQuestions for
your review.
Is WORM the only permitted electronic preservation approach?
No. The amended rule also provides an audit-trail alternative. The chosen system must meet the applicable requirements for that approach and the wider rule.
Does an ordinary transfer log satisfy the audit-trail alternative?
Do not assume it does. The alternative concerns the preserved record and the ability to recreate it, not simply a list of delivery events.
Does this page claim MX meets Rule 17a-4?
No. It explains evaluation questions. Verify the exact service, configuration and recordkeeping arrangements before relying on any compliance claim.
Can every record use one retention period?
No. Identify the category and applicable retention requirements. Confirm the schedule with your compliance team rather than applying a single period to every file.