We are seeing an increased regulatory focus on the preservation of trading and robo advising algorithms. For instance, if a robo advisor advises a particular purchase, the code behind that recommendation needs to be retained and available if called upon by a regulator. Software developers have systems but often the question as to what code was running at a specific time and the non-erasable evidence of the ‘chain of custody.’ It is now incumbent upon the compliance department to make sure that the software developers adhere to corporate preservation policies.
About 17a-4, llc
17a-4, llc provides regulated clients with consulting services and software to assist in compliance with SEC Rule 17a-4, Rule 204-2 FINRA 3110 and other financial regulations. 17a-4, llc provides a number of products and services including Designated 3rd Party (Rule 17a-4(f)(3)(vii)), eDisclaimer and configuration of Microsoft’s O365 for non-erasable compliance (Preservation Lock).