17a-4 Services

Compliance Services

Financial institutions have a complex web of regulations and technologies to manage in order to stay in compliance.  To successfully address all relevant aspects requires knowledge of compliance, legal and IT issues that impact regulated financial institutions.  17a-4 has worked with financial firms since 2001 to implement archival and messaging technologies and to develop compliance policy and procedures.  To address our client’s requirements; 17a-4 has developed a suite of services and productions including:

  • Letter of Undertaking.  A Letter of Undertaking is required by the ’34 Act designating a 3rd party as able to assist the SEC or other regulator should internal resources not be available.  (Rule 17a-4(f)(3)(vii)).
  • Annual Compliance Review.  A review of any new or changed regulation, e-messaging technologies or appropriate policies.  This will provide a document that may be incorporated into a broader institutional compliance document such as an Annual Review (Rule 206(4)-7), Rule 38a-1, SOX or other compliance policy document.
  • Annual Technical Review.  An audit to insure that institutional policies are effectively implemented in the archive infrastructure.  For instance, if EU email are not archived based upon policy, then we confirm that in fact that exclusion rule has been incorporated into the archive software.
  • Supervisory Lexicons.  As we work closely with clients on regulatory audits and developing policy, we are aware of the words/ lexicons which should be monitored.  We will make updates available to supervisors to determine whether the word/ phrase should be incorporated into their lexicon.
  • Regulatory Examination Support.  Clients ask 17a-4 to participate in their regulatory examination or regulatory productions as 17a-4’s knowledge of e-messaging formats and ‘best practices’ is often invaluable in a time-critical e-Discovery.  Additionally, we advise as to which types of messaging should not be in the archive, to ensure productions contains only necessary responsive items.
  • e-Discovery Productions.  Our support for e-Discovery productions include:
  • Constructing search using wildcards, proximity, and Boolean operands;
  • Determining canonical name and other name variations;
  • Verifying legal / regulatory holds;
  • Assisting with privilege logs and review;
  • Formatting messages in accordance with production requirements.