In a message in reply to Laura Bolt message Larry Medina stated:

"E-mail IS NOT A RECORD SERIES.  E-mail is the conveyance the information
arrives or is sent by, and the retention period should be based on the
content of the e-mail itself"

I am not sure I agree with Larry and others who have basically stated the
same thing.  For some reason I believe I remember that our retention
schedule for a company I worked for in a past life had established the
retention period for the rotation of the backup tapes as part of the IT
processes and procedures. 

If a backup tape can be considered a series, why not E-Mail if used to
retain the information of all email for a specific period of time.  While an
individual email message must be identified by content, filed, and retained
just like records in other formats the contents of all email received could
be saved for a specific period of time as established by the internal policy
of the organization, i.e., a backup system for email messages only that
would be documented on the retention schedule with the specific retention
requirement. 

An example would with the SEC requirement for retaining email/IM, etc., of
individuals who work as broker/dealers.  Their emails are required to be
backed up.  No distinction of content is established (except they are
broker/dealers).  

Now I would guess that each message received is also filed in electronic
and/or paper format based on content (client name, etc.,) to confirm sale or
discussion.  

If my logic is correct you could have two separate records series for the
same information with two separate retention periods.

One for:  

E-Mail which I believe still has a three (3) year retention period. (17 CFR
240-17(a)-4)

E-Mail and/or other format copy filed as part of the client file which would
be retained for xxx number of years.  Possible as long as the client does
business with the company. (17 CFR 240.17a-4(c))

Just my thoughts on the subject on a cold rainy day in the rainy, rainy
Pacific Northwest.

Bob Dalton, CRM
Dalton Consulting
1-253-229-4555
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