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Write Once Read Many (WORM)

  • 1.  Write Once Read Many (WORM)

    Posted 08-05-2020 11:28
    Seeking for a Write Once, Read Many (WORM) Solutions to meet the SEC 17a-04 Requirements that will work with Genesys Cloud.  Anyone here have a recommendation they are using?

    Overview of Regulatory Requirements:

    • SEC requirements ("WORM" or 17a-4") – SEC rule that covers requirements for broker-dealer record retention, and how they are preserved. Records must be kept on a write-once-read-many ("WORM") storage. SEC requirements specify minimum requirements with respect to the records that broker-dealers must make, how long those records and other documents relating to a broker-dealer's business must be kept and in what format they may be kept. The SEC requires that broker-dealers create and maintain certain records so that, among other things, the SEC, self-regulatory organizations ("SROs") and state securities regulators may conduct effective examinations of broker-dealers.

     

    In other words, someone must have 'keys to the kingdom' to provide true and complete records (that cannot be altered or deleted) to a regulatory body if needed.  DSL must file with FINRA prior to using any new Electronic Storage Media ("ESM"). Currently Global Relay is a WORM/17a-4 compliant vendor for DSL.

     

    • FINRA requirements:
      • FINRA requires that firms have procedures to review electronic correspondence (including chat, emails, teams messages, etc.)  including incoming, outgoing and internal correspondence. This review is to identify and handle customer complaints, and communications that are of a matter that require review under FINRA rules or securities laws. The review of correspondence must be conducted by a principal of DSL for registered representatives/securities related communications.
      • FINRA Rule 3110.07 requires the principal review must record the reviewer, the specific communication reviewed, the date of the review, and the actions taken regarding issues identified
      • Both the correspondence and the principal review are books and records of the firm – meaning that they must be retained in 17a-4 compliant matter (which Global Relay satisfies for us today)


    Thank you
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    Lee Canady
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  • 2.  RE: Write Once Read Many (WORM)

    Top 25 Contributor
    Posted 08-08-2020 19:41
    Genesys Cloud as it is should meet these requirements.  Once records and recordings are written, you cannot change that information, so that should cover the SEC rules.  You can read as may times as you like, but not make any changes to the information written.  Also, audit trails, encryption and access controls should suffice for the FINRA rules.  As far as the deletion, that is up to the policy you specify, so you can make it meet any requirements you have - Genesys will not limit you there.  I suggest you just move recordings into Archive after 90 days or so and keep them there.

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    Robert Wakefield-Carl
    Avtex Solutions, LLC
    Contact Center Innovation Architect
    robertwc@avtex.com
    https://www.Avtex.com
    https://RobertWC.Blogspot.com
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