Content Manager 25.1 Content Manager

# About SEC Rule 17a-4 Compliance rules

SEC compliance is a regulatory framework for financial institutions governing the way to manage documents relating to financial transactions. Although it is a US-legislated requirement, it affects most large financial institutions as they are multi-national. It is covered by SEC Rule 17a-4 - see Wikipedia https://en.wikipedia.org/wiki/SEC_Rule_17a-4. The rules for immutability are well explained in the following document https://www.sec.gov/rules/interp/34-47806.htm

The implementation in Content Manager is as follows:

- On the document store, there is a flag called Implement SEC Rule 17a-4 Compliance rules available. If it is turned on, then a destruction date needs to be provided at the time of adding a document to this store.

The business logic that calculates the destruction date of a document will be modified to also calculate a "storageDestructionDate":

- For new records, this will be either the date calculated from the retention schedule or the manually specified destruction date. If the store is "SEC compliant" and the storageDestructionDate is blank for whatever reason, then an error is raised. This storageDestructionDate is passed along with the document store request.
- For existing records, if the normal scheduled destruction date is changed, and if the record is stored in an SEC compliant store, then this new date is compared to the "storageDestructionDate". If the new date is non-blank, but before the storageDestructionDate then the new destruction date is set to the storageDestructionDate. If the new date is after the storageDestructionDate the document store is notified of the new retention date and the storageDestructionDate is adjusted upwards. So, the storageDestructionDate acts like a high watermark.

The following additional business rules will apply to records that are stored in an SEC compliant store:

- No check in or check out, or related functionality, and therefore no previous revisions will exist.
- The Delete Document menu item will not be available
- Record Types marked with the flag Automatically declare as final once electronic document is attached will not be useable from the Microsoft Office integration
- Delete Record will not be allowed if the storageDestructionDate has not been reached
- Destroy Record (or adding to any destruction consignment) will not be allowed if the storageDestructionDate has not been reached
- If a record type has an SEC compliant store specified, then records of that type will be automatically declared as final once a document has been attached. See Record Type Electronic page
- The record type "Create new revision, replace existing revision" will be disabled.
- Retention Schedules disposal types "Archive (Keep Forever)", "Archive (Transfer Custody)" and "Make Inactive" will display that they are invalid for records that comply with SEC Rule 17a-4.
- SEC compliant stores will not be able to be added to the storage pool.
- The SEC compliance flag cannot be modified once a document store has been created.
- Cannot set a manual destruction date prior to the storage destruction date.
- No document transfers from or to an SEC compliant store

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Version 25.1 | Last updated January 2025
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Product: Content Manager 25.1

Topic Title: About SEC Rule 17a-4 Compliance rules