Comments on an SEC proposal to amend broker-dealer and security-based swap dealer electronic recordkeeping requirements are due by January 3, 2022. The proposal was published in the Federal Register.

As previously covered, the proposal would do away with the requirement that records be kept in a non-rewriteable, non-erasable format (better known as "write one, read many" or "WORM"). The SEC proposed these amendments because the current version of the broker-dealer electronic recordkeeping rule does not accommodate contemporary electronic recordkeeping systems. The proposed changes are intended to (i) make the rule "technology neutral," such that it is compatible with future electronic recordkeeping innovations, (ii) improve electronic recordkeeping requirements and (iii) facilitate inspections and examinations.

Primary Sources

  1. Federal Register: Electronic Recordkeeping Requirements for Broker-Dealers, Security-Based Swap Dealers, and Major Security-Based Swap Participants

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.