15a-6 Sharepoint Platform
Support for Rule 15a-6 and Chaperoned Research
SEC Rule 15a-6 seeks to “to facilitate access to foreign markets by U.S. institutional investors through foreign broker-dealers and the research that they provide, consistent with maintaining the safeguards afforded by broker-dealer registration.”
The SEC DeskTop provides a very simple, integrated workflow platform based on Microsoft’s Sharepoint Online (Office 365) that allows U.S. broker/ dealers to:
- International financial institutions can email research to a Sharepoint library.
- The compliance team will be alerted of new, pending research.
- A reviewer can easily open and review the research using all of the tools available in both Microsoft’s Outlook and Office products.
- The reviewer will then categorize the research as appropriate.
- If approved, the research may then either be automatically uploaded onto a shared Sharepoint Online site or sent as an email to a list of institutional clients.
- All research and reviews are retained on Sharepoint with the appropriate retention policies and Microsoft’s Preservation Lock. These settings allow the research to be retained in accordance with SEC Rule 17a-4.
- 17a-4, llc will provide a Letter of Undertaking (Rule 17a-4(f)(3)(vii)) and a Letter of Notification (Rule 17a-4(f)(2)(i)) for the U.S. Broker/dealer to file with FINRA.