Archive Solution
FivePoints' archive solutions are powered by technology from Sony
(AIT3 WORM) and EMC (Centera). While our standard offering includes
a three-year archive, this can be extended based on your firm’s
needs.
Example: You are a public company and under Sarbanes-Oxley
regulations you have determined that you should store your communications
for seven years or a message or group of messages must be saved
for a longer period of time.
The point is that you decide when to delete, we don’t.
The SEC has mandated that certain type of books and records be
maintained by a broker-dealer for specific lengths of time. SEC
rules 17a-3
and 17a-4
require extensive record keeping including email. An overview of
archiving regulations can be briefly summarized below.
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Messages (original and duplicate) needs
to be preserved exclusively |
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Non-rewritable, non-erasable formats |
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You must be able to verify automatically the quality
and accuracy of the archiving process |
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Original and duplicate messages must be fully indexed
and searchable |
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Full audits of the messaging archive environment
must be provided |
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Messages must be maintained for 3 years, the first
2 of which must be in a readily available location |
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Surveillance Solution
NASD rule
3010 and NYSE rule 472 require that registered members must
maintain a corporate policy regarding electronic communications
and their surveillance. They also require that a sampling of communications
between registered representatives and the public must be reviewed.
Further there should be in place a method by which to check for
keywords commonly used by registered reps when performing illegal
conduct.
FivePoints has extensively reviewed industry practices
and the larger overall compliance community to develop a standard
set of best practices, which is incorporated into our base surveillance
product. In addition, communications have been classified by type
and content.
Our service performs a set of screening procedures for e-mail and instant messaging, ensuring that the base set of industry standards are performed for all forms of electronic communication.
We offer clients the ability to customize their set of rules based upon their business practices. The customization process involves a comprehensive review of your firm’s business practices and communications, as well as the overall supervisory structure. The result of this review is a custom-tailored surveillance process that meets your firm’s unique needs.
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