Aug. 31, 2022
August 31, 2022 It seems the proposed rule actually weakens processes in place that help protect the investor. Currently under 17a-4 broker dealers are required to store data in a WORM format which maintains the integrity of the data. The proposed removal of the requirement around immutable storage opens the door for data manipulation. Additionally, under 17a-4 there is a requirement for an independent third party to have access to records that fall under the scrutiny of the SEC. This is provides the SEC with additional options for obtaining data when a broker dealer chooses not to comply with a request. The proposed change removes this requirement and creates a significant gap by asking for a person at the firm to take the role but does nothing to ensure a proper methodology exists for obtaining data an ensuring true transparency.