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 (e.g., NASD, OTC)
 

The following section is intended to present the major records required under SEC rule 17a-3, the frequency with which each must be generated or updated and the retention period for each as established by SEC rule 17a-4.

What?

Blotters and other records of original entry - (Trade Tickets, Journal Entries etc.) - that detail the following:

  • All Purchases and Sales of Securities
  • All Receipts and Deliveries of Securities
  • All Receipts and Disbursements of Cash
  • All other Debits and Credits

Each record should provide the following information:

  • The account for which the transaction was effected
  • The name and amount of the security
  • The purchase or sale price
  • The Trade Date
  • The person from whom securities were bought or received or to whom securities were sold or delivered

How Often?

Must be updated no later than the first business day following the transaction.

How Long?

Must be retained for at least 6 years.

***

What?

Ledgers or other records that reflect all the firms assets and liabilities, and the balance of all income, expense and capital accounts.

How Often?

Must be updated daily.

How Long?

Must be retained for at least 6 years.

***

What?

Account ledgers or records that record for each account all purchases, sales, receipts and deliveries of securities and commodities - and all other debits or credits to those accounts. These records must distinguish between transactions effected in Cash Accounts and those effected in Margin Accounts.

How Often?

Must be updated no later than the first business day following the transaction.

How Long?

Must be retained for at least 6 years.

***

What?

Ledgers or records reflecting the following:

  • Securities in Transfer
  • Dividends and Interest Received
  • Securities Borrowed and Loaned
  • Monies Borrowed and Loaned (and any associated collateral)
  • Any security or money difference identified in the firm's books and records
  • All Repurchase and Reverse-Repurchase Agreements

How Often?

No later than 2 business days following the transaction date.

How Long?

Must be retained for at least 3 years.

***

What?

Ledgers or records reflecting any Failed Receives (Fail-to-Receive) and Failed Deliveries (Fail-to-Deliver).

How Often?

Must be updated the next business day following Settlement Date.

How Long?

Must be retained for at least 3 years.

***

What?

A Securities or Stock Record reflecting - for each security - all long and short positions maintained by the firm for the benefit of itself, its partners and/or its clients. The Securities Record must identify where securities are held by the firm (ie. DTC, Physical Vault, Foreign Depository etc.) and should identify any differences resulting from accounting or processing errors.

How Often?

Must be updated daily.

How Long?

Must be retained for at least 6 years.

***

What?

A record of each brokerage order received for the purchase or sale of securities, and the specific terms of that order - regardless of whether the order is executed or unexecuted. The record must include the account for which entered, the time of entry and the order price, and if executed the execution price and, if feasible, the time of execution. Any modification or cancellation of orders must also be noted on the record.

How Often?

Must be updated at the time of entry, modification, execution or cancellation.

How Long?

Must be retained for at least 3 years.

***

What?

A record of each purchase and sale - including the execution price and - "to the extent feasible" - the time at which the trade was executed.

How Often?

Must be updated at the time of the transaction.

How Long?

Must be retained for at least 3 years.

***

What?

Copies of all trade confirmations - including notices of other debits or credits for securities and cash resulting from brokerage or other transactions.

How Often?

Must be updated on the day of the transaction or on the following business day.

How Long?

Must be retained for at least 3 years.

***

What?

The name and address of the beneficial owner for each brokerage account - cash and margin - maintained by the broker dealer. For Margin Accounts, the signature of the beneficial owner must also be maintained.

How Often?

Must be updated prior to the entry of any transactions for the account.

How Long?

Must be retained for the life of the account plus an additional three years.

***

What?

A record of all options - including puts, calls, straddles or spreads - in which the firm has a direct or indirect interest.

How Often?

Must be updated no later than the business day following the transaction.

How Long?

Must be retained for at least 3 years.

***

What?

A record of all money balances in the form of a 'trial balance' and a record of the computation of aggregate indebtedness and net capital as required by the SEC Net Capital Rule - 15c3-3.

How Often?

Must be updated no later than 10 business days after the close of the accounting period.

How Long?

Must be retained for at least 3 years.

***

What?

The firm must retain all "questionnaires" or applications for employment.

How Often?

Must be updated prior to the commencement of employment.

How Long?

Must be retained for the period of employment plus at least 3 years after the termination of employment.

 





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