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Naremco Services Inc. |
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Jesse Wilkins wrote:
> 17 CFR 240.17a-4 requires that broker/dealers keep REQUIRED
> communications regardless of media for three or six years depending on the
> nature of the communication.
>
> So it's not every single communication, but only relevant ones.
Jesse -- see below
> 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???
Greetings from London!
Larry -- remember your own postings! From the RECMGMT-L Archives:
Date: Wed, 17 Nov 2004 14:47:46
Sender: Records Management Program
From: Larry Medina
Subject: RAIN: SEC wants unfettered access to E-Mail
http://www.pf.com/law_internet_digitaldisc.asp
SEC Enforcers Want Unfettered Access to E-Mail
Securities and Exchange Commission officials appearing at a conference
sponsored by the American Law Institute-American Bar Association in Washington,
D.C., clarified the Commission's approach to e-mail. The short version is that
when SEC investigators probe possible wrongdoing involving a broker-dealer,
they will insist on access to all of the subject's e-mails that have been sent
over corporate systems, including personal messages.
On November 5, John Walsh, chief counsel in the SEC's Office of Compliance
Inspections and Examinations, said that in inspections, the staff is requesting
e-mails pursuant to the agency's authority to examine all records, whether or
not a legal requirement for their retention exists. ...
Al
--
Alan A Andolsen CMC CRM
President
Naremco Services Inc.
60 East 42nd Street
New York, NY 10165
Voice: 212-697-0290
Fax: 212-986-1736
MailTo:[log in to unmask]
URL: http://www.naremco.com
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