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Subject:
From:
David Gaynon <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Thu, 26 Feb 2009 12:08:50 -0800
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 I must say that controls over the use of technology is not just an issue for government employees and contractors. In certain financial services there is a requirement that all communication with customers or potential customers is subject to a supervision program. See for example

http://finra.complinet.com/en/display/display.html?rbid=2403&record_id=4395&element_id=3717&highlight=supervision#r4395

Look under review of transactions and correspondence.

"Each member shall develop written procedures that are appropriate to its business, size, structure, and customers for the review of incoming and outgoing written (i.e., non-electronic) and electronic correspondence with the public relating to its investment banking or securities business, including procedures to review incoming, written correspondence directed to registered representatives and related to the member's investment banking or securities business to properly identify and handle customer complaints and to ensure that customer funds and securities are handled in accordance with firm procedures. Where such procedures for the review of correspondence do not require review of all correspondence prior to use or distribution, they must include provision for the education and training of associated persons as to the firm's procedures governing correspondence; documentation of such education and training; and surveillance and follow-up to ensure that such procedures are implemented and adhered to. "

David Gaynon
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