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Colton Wright
Colton Wright

Six Features A D3P Needs To Make The Cloud 17a-4 Compliant !!TOP!!

Immutable storage for Azure Blob storage enables users to store business-critical records in a write once read many (WORM) state. This state makes the data non-erasable and non-modifiable for a user-specified interval. For the duration of the retention interval, blobs can be created and read, but cannot be modified or deleted. These features of Azure immutable storage can help customers address their records retention requirements.

Six Features a D3P Needs to Make the Cloud 17a-4 Compliant

For SEC 17a-4(f) requirements, Cohasset validated that Microsoft 365 includes archiving features that enable regulated customers, including broker-dealers, to store data in a manner that helps them comply with SEC requirements for records retention. Retention features in Microsoft 365 help preserve a wide range of data, including email, voicemail, shared documents, instant messages, and third-party data. In particular, archiving in Microsoft 365 enables customers to set global or granular messaging retention policies to store data for a defined period and beyond in a non-rewriteable, non-erasable format.

About AdvisorVaultAdvisorVault is the only FINRA D3P giving small firms everything needed to meet rule 17a-4. Our turn-key solution, archives, retains, and provides supervision of electronic records stored in-house or in the cloud.

2.Books and Records Archiving: Once a full email archiving process is in place, FINRA members need to make sure data contained in the books and records is properly archived with the D3P. The difficulty here is that books and records data is contained throughout the firm in many different formats such as Office documents, scanned files, data bases, and branch offices or uploaded to the cloud. The key here also is to make sure all this data is easily stored in an SEC format compliant with the electronic records archiving rules of SEC 17a-4. Therefore, the D3P must have an automated method to connect to all these various systems, make a copy of the data stored on them so it can be transferred to 17a-4 compliant storage. In addition, the D3P also has to offer the FINRA firm a few added features to achieve the ongoing supervisory rule of 17a-4:

FINRA Rule 4511 (General Requirements) requires firms to: (1) make and preserve books and records as required under the rules of FINRA, the SEA and the applicable SEA rules; and (2) preserve the books and records required to be made pursuant to the FINRA rules in a format and media that complies with SEA Rule 17a-4. In addition, FINRA Rule 4511 requires firms to preserve for a period of at least six years those FINRA books and records for which there is no specified retention period under the FINRA rules or applicable SEA rules. This six-year retention period is a default retention period for those FINRA rules that require firms to preserve certain books and records, but do not specify a retention period, and where there is no retention period specified under the SEA rules. In the absence of contrary guidance in a rule, if the books and records pertain to an account, the retention period is for six years after the date the account is closed; otherwise, the retention period is for six years after such books and records are made. 041b061a72


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