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Subject:
From:
"Bradley, Mary" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 23 Mar 2012 15:52:23 +0000
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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) 
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