4d. BD LAB – Modernizing Records Management:  One Year Later (Advanced - CLOSED) 

The SEC amended Rule 17a-4 on October 12, 2022, to modify the requirements regarding the maintenance and preservation of electronic records.  Regulatory findings continue to drive significant penalties and firms can expect exam focus on books and records in the coming year.  This session provides compliance and legal professionals guidance on testing firm processes, procedures and systems relating to records creation, retention, and supervision. 

This session is closed to both regulators and members of the press.

The following learning objectives will be met using case studies, examples, group discussions, and other hands-on activities:

  • Discuss best practices for meeting the Audit Trail Alternative requirements; learn how other firms are evaluating, supervising, and documenting the Audit Trail Alternative now that the practices have been in place for one year.

  • Analyze the pros and cons of on-premises electronic record storage vs cloud storage – including data privacy and security and how to assess vendors’ contracts to understand if partners can comply with recordkeeping requirements.

  • Manage examination production, "legal holds," enforcement matters, and destruction of records and information – when and how it should be done.

  • Consider best ways to vet and oversee third-party records systems, including trading platforms, email, and digital engagement platform supervision providers. 

  • Discuss best practices for testing, including vendors’ capabilities to fulfill regulatory obligations.


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4c. BD - Remote Supervision Pilot program and Residential Supervisory Locations (Intermediate - OPEN)

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4e. IA – The Marketing Rule in Year 2:  More Lessons Learned (Intermediate - OPEN)