Electronic Storage of Records
Clearly, if kept in paper form, the volume of books and records that Rules 17a-3 and 17a-4 require broker-dealers to make and keep could rapidly engulf an office in a sea of files. Fortunately, Rule 17a-4 permits storage of records on micrographic media—i.e., microfilm or microfiche—which isn’t much used anymore, or electronic storage media, which is.
If a broker-dealer intends to use electronic storage media, it must advise its designated examining authority in advance; if it plans to use any media other than CD-ROMs or other optical disk technology, it must notify the authority at least 90 days in advance. The broker-dealer or the storage media vendor has to provide a representation that the storage media meets the following requirements:
- • The media preserves the records in a non-erasable, non-rewritable format.
- • The media automatically verifies the quality and accuracy of the recording process.
- • The media serializes the originals and any duplicates.
- • The media time-dates the information recorded.
- • The media has the capacity to readily download records and indexes.
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