WORM archives for regulated firms can become quite large and when the move to a new platform is needed, migration and compliance are the two main topics. One can easily argue for full migration of all archived data but if you have experienced a migration, you know all too well they are often long, difficult, and expensive projects. There is a middle ground. A hybrid approach here entails migrating some content and leaving the rest behind to “age out” in the old archive system. There are decisions to be made as to what stays and what goes as well as how the legacy archive system will be supported and managed but the cost and complexity of a full migration can be avoided. Disposition polices on the old archive will ensure cost will continue to drop as the store decreases and license fees can be drastically reduced to allow for only one or two user access licenses for any needed legal or eDiscovery matters.
Clients that go with this hybrid migration approach must remember to stay in compliance with Rule 17a-4 and maintain D3P coverage for non-production repositories with data being retained until disposition milestones are met. 17a-4 Compliance Services team helps clients determine what data gets migrated and what should stay behind whether based on age, specific data type, user groups etc. Recommendations for how to manage the old archive, dispose of data, perform eDiscovery and transition data sources to the new archive are provided.
17a-4, LLC is the leading D3P (Designated Third-Party) services for US broker dealers. As archive vendors focus on keeping market share and enhancing features in their products, they lean on experienced partners to help clients with accompanying services to meet business, operational or compliance requirements. 17a-4 has a deep knowledge of how archive technologies work, including access and maintenance with minimal cost.