I recently had a client who is reworking their records program to meet SEC
17a-3/4 compliance.  Some of the records that are required to be kept reside
within an electronic database.  One of the discussed options for meeting the
regulations are to generate a report of the data required and store this
report as the official record, since the actual data is spread across
database tables that are dynamic in nature.  
 
So my first question is does anyone know if generating a report containing
the SEC required data and storing this as a record suffice for compliance?
(I guess the question is - what is considered the record?)
 
And, if not, is the alternative to backup the entire database and system
that uses it onto CD-ROM or equivalent storage in order to meet SEC 17a-4?
 
Also, when it comes to destroying those report records it may still be
possible to re-generate them from the database.  Are those records then
still considered destroyed from a litigation risk perspective, or, by the
fact the database may still contain the information, duplicate copies still
exist?
 
Any help would be appreciated, thank you
 
Tim Shinkle
President
Perpetual Logic, LLC
1005 N. Pitt Street
Alexandria, VA
22314
(703) 927-5650
www.perpetuallogic.com <http://www.perpetuallogic.com/> 
 

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