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Records Management Program <[log in to unmask]>
Date:
Wed, 20 Dec 2006 13:35:52 -0500
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Records Management Program <[log in to unmask]>
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Peter Kurilecz <[log in to unmask]>
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On 12/20/06, Larry Medina <[log in to unmask]> wrote:

>
>
> Can anyone confirm this comment from the above article?
>
> "Securities and Exchange Commission rules require that firms keep all
> e-mails and business communications for three years."
>
> Is it true that "...ALL e-mails and business communications..." must be kept
> for 3 years, or only those pertaining to certain types of transactions???

here is the relevant citation

§ 240.17a-4 Records to be preserved by certain exchange members,
brokers and dealers.

(b) Every member, broker and dealer subject to § 240.17a-3 shall
preserve for a period of not less than three years, the first two
years in an easily accessible place:

(4) Originals of all communications received and copies of all
communications sent (and any approvals thereof) by the member, broker
or dealer (including inter-office memoranda and communications)
relating to its business as such, including all communications which
are subject to rules of a self-regulatory organization of which the
member, broker or dealer is a member regarding communications with the
public.

so the minimum timeframe is 3 years, doesn't mean they cann't keep it
longer It all depends upon what retention decision was made by the
firm. It is my understanding that most if not all brokerages have
decided on the 3 year.

note that the regulation states 'ALL COMMUNICATIONS" it does not
differentiate between emails and any other type of communication. The
devil is in the details
-- 
Peter Kurilecz CRM CA
Richmond, Va

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