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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.

View other products from 17a-4, llc

DataParser captures 3rd party content for archival retention

DataParser is the leading middleware tool to capture content for regulatory compliance. It is a simple, cost-effective software tool that preserves the integrity and 'chain of custody' of the messages so that it may be used in either a regulatory production or in litigation. The DataParser supports: Bloomberg Blackberry Symphony Reuters Eikon Slack Cisco Jabber …

eDiscovery productions from collaborative platforms

Availability of the DataParser for Legal eDiscovery ‘fire drills’ Under the Federal Rules of Civil Procedure, Rule 26(a)(1)(A)(ii), corporations must disclose available electronically stored information that supports its claim or defense.  To prepare for litigation, legal teams now need to develop and document the necessary procedures to access such content and the associated costs. Millbrook, …

Designated 3rd Party Services (SEC Rule 17a-4(f)(3)(vii))

As required by SEC Rule 17a-4(f)(3)(vii)), we provide both Letters of Undertaking and Notification (Rule 17a-4(f)(2)(i).  We review the platforms which clients use to retain electronic compliance records including email, Sharepoint, IM, social media and financial records.  We have a deep expertise in the types of hardware and platforms which may be configured to support …