SEC Rule 17a-4(f)
Requirement Summary
|
Provided by Fiserv
|
| Preserve the records
exclusively in a non-rewriteable, non-erasable format |
Currently, the only authorized formats
are optical disk storage or WORM (Write Once Read Many) technology
in its various forms, such as DVDs and CDs. Fiserv's approach
costs up to three times less than optical tape or disk and
tailors each client’s archival medium according to the
size and need of the account. Again, the storage media must
be "Write Once Read Many"—meaning DASD does not currently
comply. |
| Verify automatically
the quality and accuracy of the storage media recording process |
Each step of the Fiserv process is
scheduled, monitored, and reported by the Automated Report
Processing module to reroute potentially suspect files to an
exceptions queue for validation, define retention periods,
and to route the data to near line storage as required. |
| Serialize the
original and any duplicate units of storage media, and time-date
for the required period of retention |
All recorded data is serialized
during each production run, in addition to physical markings
on each original and duplicate medium. Data is retained for
a specified period of time and is available for search and
retrieval from a single interface. |
| Have the capacity
to readily download electronic indexes and records to any medium
acceptable under this rule as required |
Fiserv utilizes a flat-file format
to store indices. This provides the ability to download indices
for search and retrieval of records and attachments. This also
increases search and retrieval speeds. Additionally, archived
statements can be faxed, e-mailed, or printed directly from
the archive. |
| At all times have
easily readable projection or productions of micrographic media
or electronic storage media images available for examination |
Access to archived copies of statements
are available from the client location at all times. Additional
back-up and disaster recovery copies are also stored in a secure
location for the entire retention period. |
| Be ready at all
times to immediately provide a facsimile enlargement which
the Commission or its representatives may request |
Authorized archive administrators
(designated by the client) are able to search for, retrieve,
and distribute archive statements. This includes the ability
to batch print and enlarge the copy as needed. |
| Store a duplicate
copy of the record separately from the original on any medium
acceptable under ss240. 17a-4 for the time required |
With each production cycle, copies
of archived statements are delivered to the authorized client
archive administrator and also stored in a secure location. |
| Organize and index
accurately all information maintained on both the original
and any duplicate storage media, making all indexes available
for examination at all times |
Fiserv organizes and indexes archived
statements in a way that is intuitive and easy to use. Indexes
are stored with the information to provide instant search and
retrieval of archived information as well as from all duplicate
copies. |
| Each index must
be duplicated and stored separately from the original copy
of each index. Original and duplicate indexes must be preserved
for the time required for the indexed records |
Fiserv indexes are stored with the
data, including all duplicate copies, to ensure the indexes
are accessible at all times. |
| An audit system
must be in place that provides for accountability regarding
inputting of records required to be maintained-and any changes
made to the original-and preserved pursuant to ss240. 17a-4
and 17a-3 |
Each step of the statement archival
process is systematically tracked, recorded, and reported during
each production cycle. This includes data transfer and production
logs, quality assurance certification, and ongoing tracking
of the archived inventory. "Changed originals" are treated
as separate items and archived accordingly. |
| All results of
such an audit must be available for examination at all times
and preserved for the time required for audited records |
Regularly scheduled and ad-hoc audit
reports are provided. |
| All information
necessary to access records and indexes stored on the electronic
storage media must be kept current and accessible; or placed
in escrow with the appropriate documentation and information
necessary to access records and indexes |
All archived statement information
is stored with the indexes and is accessible to authorized
users at all times. |
| For every member,
broker, or dealer exclusively using electronic storage media
for record preservation under this section, at least one third
party who has access to and the ability to download information
from the electronic storage media to any acceptable storage
medium |
Fiserv, the Electronic Document
Delivery and Storage Solution Provider, currently acts as the
SEC-designated third party archival service provider to a number
of major NYSE members who clear trades for up to 40% of the
industry's broker dealer community. |
