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Records Management Program <[log in to unmask]>
Subject:
Re: SEC & e-mail Question
From:
"Piotrowski, Charles" <[log in to unmask]>
Date:
Mon, 11 Apr 2005 10:11:23 -0400
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Records Management Program <[log in to unmask]>
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Thanks!

It is a bit more nuanced than the article states (as I wondered)...

"Every such broker and dealer shall preserve for a period of not less
than 3 years, the first two years in an accessible place:..."

        "Originals of all communications received and copies of all
communications sent by such member, broker or dealer (including inter-
office memoranda and communications) relating to his business as
such."


Source: http://www.law.uc.edu/CCL/34ActRls/rule17a-4.html

I wonder what is "accessible" and who decides that?!

- Chuck


-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On
Behalf Of Tod Chernikoff
Sent: Monday, April 11, 2005 10:00 AM
To: [log in to unmask]
Subject: Re: SEC & e-mail Question

Chuck:

I don recall if it is by medium or content, but you can look at the
regulations at:

SEC Rule 17a-3: http://www.law.uc.edu/CCL/34ActRls/rule17a-3.html and
SEC Rule 17a-4: http://www.law.uc.edu/CCL/34ActRls/rule17a-4.html
General Rules Index:  http://www.law.uc.edu/CCL/34ActRls/reg19B.html

Tod Chernikoff, CRM

On Mon, 11 Apr 2005 09:36:42 -0400, Piotrowski, Charles
<[log in to unmask]>
wrote:

>Happy Monday!
>
>I read the RAIN today and the article "E-MAILS become trial for
courts,"
>in the Chicago Tribune was very provocative and worth sharing with your
>General Counsel.
>
>I did have a basic question:
>
>The article stated "The SEC requires securities firms to preserve
>e-mails for two years."
>
>Since I don't work in a securities bureau I am a bit unlearned here. I
>seek a point of clarification. Did the SEC put this retention on the
>medium (e-mail) and not the content? Is it all e-mails regardless of
>content?
>
>Just curious!
>Thanks
>
>Chuck Piotrowski
>CVPS
>www.cvps.com
>This computer runs on Cow Power!
>
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