Tod Chernikoff <[log in to unmask]> wrote:

>As was noted later by another, records relating to these should be retained
under the normal schedule for advertising. Good idea to keep a copy of the
addresses list.  As was further noted, once a reply is made (be it through
redirected reply address or through an embedded link) to the actual
broker/dealer, then the broker/dealer retention rules apply to those
applicable communications.
>

(Snipped down to the tasty parts)

Having worked for (Company to remain nameless) during/following the major
fiasco they went through where some of the marketing was later ruled on as
being an attempt at "churning", I recall what the SEC ruled regarding
advertising materials for them, but this was based on the findings. 

ALL Advertising materials were to be retained for a minimum of 5 years after
the product ceased to be offered, including any changes made (versions,
updates) to materials on ALL products.  A complete mailing/e-mail list of
ALL clients they were provided to, INCLUDING face-to-face meetings or
walk-ins was to be retained for the same time frame. 

All calls were recorded and each broker had to keep a daily log of the
product offerings discussed with clients, and it had to indicate who
initiated the discussion.  They used a worksheet that included a list of all
the products with check boxes in multiple columns to indicate "offered" and
"requested", and if a transaction was entered into, that was a whole
different process. 

Monthly reports had to be generated by EACH OFFICE regarding the activities
related to all products.

I Know this practice went on for the 2 years I was working as a consultant
there (96-97) and for the 2 years after I left... not sure how long it
remained in force.

Thinking about the comment regarding what happens after client/prospective
client replies to an e-mail offer, I would think it may be advisable that a
copy of the original offer (made by e-mail) be retained in a file with that
reply to ensure you can validate what they were responding to (?)

Larry
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