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How long must a US broker dealer keep electronic records?

For the period set for each record type under the books and records rules, with the first two years in an easily accessible place, and stored either in a non-rewriteable format or under the audit trail alternative introduced in the 2022 amendments.

The answer differs between the federal level and the states, see the rows below.

The answer by level

  • Federal level

    Broker dealers preserve records electronically either in a non-rewriteable format or under an audit trail alternative, with a designated executive officer and an undertaking from a third party able to access the records.

    17 CFR § 240.17a-4
  • Sector rule

    The general books and records rule requires preservation for the period specified for each record type, with the first two years in an easily accessible place.

    FINRA Rule 4511, General Requirements
  • Enforcement

    The register entry covers the amended electronic recordkeeping requirements and the supervision rules that are examined together with them.

    17 CFR § 240.17a-4, FINRA Rules 3110 and 4511

Source lines

  • The amended rule allows an audit trail alternative alongside the traditional write once format.
  • The firm designates an executive officer with access to the records and secures an undertaking from a third party able to provide them to the regulator.
  • The supervision rules require the firm to retain communications and to evidence review of them.

What it means for the company

Enforcement in this area has centred on off channel communications. The retention obligation follows the business record, not the device or the application it was created on.

Comparison across levels and states
LevelRequirementSource
Federal levelBroker dealers preserve records electronically either in a non-rewriteable format or under an audit trail alternative, with a designated executive officer and an undertaking from a third party able to access the records.17 CFR § 240.17a-4
Sector ruleThe general books and records rule requires preservation for the period specified for each record type, with the first two years in an easily accessible place.FINRA Rule 4511, General Requirements
EnforcementThe register entry covers the amended electronic recordkeeping requirements and the supervision rules that are examined together with them.17 CFR § 240.17a-4, FINRA Rules 3110 and 4511

What it means for the individual

Registered representatives carry personal exposure where firm records are incomplete because business was conducted on private messaging.

Source lines

Next step

List every channel where business communications occur, and confirm each one is captured under the retention format the firm has elected.

All US questions

This page reports what the sources say, with the identifier and address of the publisher. It is not legal advice and does not decide an individual matter.

Next step

Three ways to put the register to work in your own practice.

Start with your task