Hi All,
I am interested in your experience with US SEC (17a-4) and CFTC (1.31) guidelines relating to record keeping, for companies using EV to journal data for regulatory purposes.
CFTC 1.31 requires:
(A) Preserves the records exclusively in a non-rewritable, non-erasable format;
(B) Verifies automatically the quality and accuracy of the storage media recording process;
(C) Serializes the original and, if applicable, duplicate units of storage media and creates a time-date record for the required period of retention for the information placed on such electronic storage media; and
(D) Permits the immediate downloading of indexes and records preserved on the electronic storage media onto paper, microfilm, microfiche or other medium acceptable under this paragraph upon the request of representatives of the Commission or the Department of Justice.
SEC 17-a-4 requires: (http://www.sec.gov/rules/interp/34-47806.htm and https://www.law.cornell.edu/cfr/text/17/240.17a-4)
(A) Preserve the records exclusively in a non-rewriteable, non-erasable format;
(B) Verify automatically the quality and accuracy of the storage media recording process;
(C) Serialize the original and, if applicable, duplicate units of storage media, and time-date for the required period of retention the information placed on such electronic storage media; and
(D) Have the capacity to readily download indexes and records preserved on the electronic storage media to any medium acceptable under this paragraph (f) as required by the Commission or the self-regulatory organizations of which the member, broker, or dealer is a member.
The regulations use the wording "all records" or "all books and records"
I am wondering how you meet these requirements in your environment. The WORM requirement seems pretty straighforward when using a Centera in Compliance Plus mode, but how do you guarantee that "all" records have successfully made it into the Centera via EV? How do you do end to end reconciliation of various channels like journaled email, Bloomberg, social media, Reuters, Salesforce Chatter, etc. ?
Thanks!