I have recently noticed that the 17a-4 electronic records request is causing serious problems for FINRA small businesses. In particular, when they are 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 disk, and hand it over to the regulator on the spot. The problem is that many companies’ electronic records are now so dispersed that they often appear empty in your file or certain data is simply not included because the IT 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’m taking the time to show businesses a few tricks to help them automate electronic record archiving. to close these gaps.
Centralization of data file 17a-4:
When it comes to achieving SEC rule 17a-4, it’s important to understand the basics of what to expect. Despite all the confusion surrounding data compliance today, FINRA companies 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, companies 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 signups. 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 that are then stored in the same cloud folder. By doing this, all data for 17a-4 withholding is stored centrally, which AdvisorVault can easily accomplish in one step.
Additionally, this sync folder can be used to consolidate the storage of other important data that needs to be archived at the designated third party for 17a-4. Such as scanned electronic records, customer database backup dumps, or exports from the CRM, while at the same time helping businesses create a truly paperless office compatible with electronic record access for anyone from any place. While ultimately keeping compliance officers and auditors happy.
To automate email archiving for 17a-4 record retention and monitoring, I suggest using Office 356 or Gmail cloud email hosting but with journaling enabled. Journaling automatically forwards all incoming and outgoing emails from the cloud provider to AdvisorVault, which is then retained for seven years in its original format; the two critical things regulators want to see. Plus, if new email accounts are added, the journal automatically captures them in real time, with no compliance or tech support required to manually add them to your 17a-4 file.
Finally, to automate disaster recovery as part of FINRA’s business continuity planning requirements, AdvisorVault includes ShadowProtect to schedule full image copies of customers’ physical or virtual servers. These images are then transferred to our 17a-4 remote storage 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 as their physical servers will not be active during a disaster. As an added measure, ShadowProtect enables granular restores of individual files or databases if needed during recovery.
Summary:
FINRA small businesses are having trouble today with requesting electronic 17a-4 records because loopholes often appear in their 17a-4 data filing process. The solution is to centralize data prior to archiving using cloud sync, journaling and ShadowProtect so 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 request for electronic records.
About AdvisorVault:
AdvisorVault, designed for small businesses, is the only FINRA Designated Third Party Provider (D3P) that has 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 your business continuity planning requirements. A complete, out-of-the-box compliance solution, right out of the box.
To request a demo of the AdvisorVault solution, click on the following link:
http://www.advisorvault.org/free-trial-offer
AdvisorVault Contact:
direct: 416-985-0310
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