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SEC 17a-4 Final Rule Updates

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The SEC 17a-4 final rule, updated under SEC 18a-6, modifies requirements regarding the use of third-party recordkeeping services to hold records. Broker-dealers and security-based swap (SBS) entities can now designate a third party to make the required undertakings or appoint a Designated Executive Officer (DEO). Review the updated requirements below.



SEC 17a-4 Designated Executive Officer Requirements

Access to records

The DEO must have the knowledge, credentials, and information necessary to access each repository, search and promptly furnish to the Commission a true, correct, complete, and current hard copies of any or all or any part of such books and records.

Format of records

The DEO must produce records in the format required by the SEC or other regulator that allows the regulator or its designee to search and sort the responsive records.

Designated specialists

The DEO is at all times responsible to fulfil the obligation but can appoint in writing up to 3 designated specialists who are employees of the broker-dealer or SBS entity and have the knowledge, credentials, and information to fulfil record requirements.




Why appoint a Designated Third Party?

Ensure compliance

A designated third party will ensure records are provided to the Commission or other relevant securities regulators promptly and in the correct format, enabling you to focus time, budget, and resources where they're needed most.

Regulation experts

Access a team of Designated Third Party specialists with the knowledge and expertise required to meet the obligations of SEC rule 17a-4 without creating additional internal burdens created by a DEO for broker-dealers and SBS entities.

Cyber security

NCC Group is a global leader in Cybersecurity meaning your records will be securely stored in our physical or virtual Cloud Escrow vault and monitored 24/7 by our Security Operations Centre.


D3P Compliance Service

Our comprehensive SEC 17a-4 D3P service is available for all types of electronic records, from cloud capabilities through to COLD (Computer Output to Laser Disk), back-office, imaged, transactional, email and messaging communications.

Our service offers compliance for an extraordinarily broad range of document management applications, including client-server to mainframe systems. Download the brochure below to find out more.

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