"Onsite" and "Easily Accessible" are distinctly different. I would seek a
clarification on the definition of 'easily accessible'.

If you have images of the documents that have pointers to the physical
location of the source documents, and the source documents can be requested
from the off-site storage location and delivered within X hours, does that
satisfy 'easily accessible'?

Larry
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-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

On Fri, Mar 23, 2012 at 8:52 AM, Bradley, Mary <[log in to unmask]> wrote:

> Hello All,
>
> I am looking for feed-back on the SEC retention regulation 204-2 that
> requires Investment Management companies to keep two years of records
> onsite or easily accessible.  We are running out of file space so I have
> been imaging our files and saving them to our network with the intention of
> sending the hard copies to off-site storage.  The transfer was denied by
> our CCO stating the SEC 2 yr. onsite requirement.  How can I prove that
> imaged documents fall under easily accessible as long as the image is
> complete, true, and legible when retrieved?  Any feed-back provided will be
> greatly appreciated.
>
> Best Regards, Mary Bradley.
>
> Mary Bradley
> The Investment Fund for Foundations
> Four Tower Bridge
> 200 Barr Harbor Drive, Suite 100
> West Conshohocken  PA 19428
> 610.684.8033 (office)
> [log in to unmask]
>

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