I have recently noticed that the electronic records request 17a-4 is causing serious problems for FINRA small businesses. Particularly when asked for a sample data set that can range from Word documents to scanned logs, emails, databases, or even the status of systems for disaster recovery. The company must then log into its 17a-4 file, download this data to a disk, and deliver it to the regulator on the spot. The problem is that many companies’ electronic records are now so sparse that there are often gaps in their file or certain data is simply not included because the technology department makes changes, such as adding new employees without knowing compliance.
So, before we implement the AdvisorVault 17a-4 Remote Data Archiving solution as part of our FINRA Designated Third Party (D3P) obligations, I take the time to show businesses a few tricks to help them automate electronic records archiving. to close these gaps.
Centralization of the data file 17a-4:
When trying to achieve SEC rule 17a-4, it is important to understand the basics of what is expected. Despite all the confusion surrounding data compliance today, FINRA firms simply need to accomplish three things: (1) archive data related to books and records, emails, and systems for disaster recovery, (2) store this file with a designated third party for seven years. and (3) ensure that this data can be made available to regulators during an audit. Doing these three things will solve 90 percent of a company’s data compliance concerns, the rest are simply procedures and documentation of the above.
First, businesses need to centralize their books and records before filing them with their FINRA D3P. For example, when using cloud storage like Dropbox, OneDrive, or Google Drive, my advice is to use the folder sync option as the default save for all registered. This option, included with all cloud storage products, places a local folder on each computer that is used to store electronic records created by each person in the company which are then saved to the same cloud folder. By doing this, all data for the 17a-4 withholding is stored centrally, which AdvisorVault can easily accomplish in one step.
Additionally, this sync folder can be used to consolidate storage of other important data that needs to be archived at the third party designated for 17a-4. Such as electronic records scanned, customer database backup dumps or exports from CRM, while at the same time helping businesses create a truly paperless office that supports electronic records access for anyone from any place. While in the end, keeping compliance officers and auditors happy.
To automate email archiving for 17a-4 log retention and monitoring, I suggest using Office 356 cloud email hosting or Gmail but with journaling enabled. Journaling automatically forwards all incoming and outgoing email from the cloud provider to AdvisorVault, which is then retained for seven years in its original format; the two critical things that regulators want to see. Plus, if new email accounts are added, the journal automatically captures them in real time, with no compliance or support required to manually add them to your 17a-4 file.
Finally, to automate disaster recovery as part of FINRA business continuity planning requirements, AdvisorVault includes ShadowProtect for scheduling full image copies of customers’ physical or virtual servers. These images are then transferred to our remote storage 17a-4 each time they are created. The key here for disaster recovery is that any version of a server image can be booted or run directly from our cloud for immediate access. This, in turn, helps businesses minimize downtime, since their physical servers won’t be active during a disaster. As an added measure, ShadowProtect allows for granular restores of individual files or databases if needed during recovery.
Summary:
FINRA small businesses are having trouble today with the request for electronic 17a-4 records because gaps often appear in their 17a-4 data filing process. The solution is to centralize the data before archiving it using the cloud sync option, journaling and ShadowProtect so that your D3P has an area to archive and retain data as required by rule 17a-4, ultimately the compliance officer you will be able to download anything requested by the regulator when they arrive for the regular electronic records request.
About AdvisorVault:
Designed for small businesses, AdvisorVault is the only FINRA Designated Third Party Provider (D3P) to have created a complete solution for 17a-4 data archiving. For a flat monthly fee, we guarantee remote backup, retention and monitoring of all electronic records for 17a-4 with full disaster recovery as part of business continuity planning requirements. A complete, out-of-the-box compliance solution, out of the box.
To request a demo of the AdvisorVault solution, click the following link:
http://www.advisorvault.org/free-trial-offer
AdvisorVault Contact:
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