Communications archiving and review

According to Rule 204-2 of the Investment Advisers Act of 1940, every investment adviser that is registered with the SEC is required to keep true, accurate and current books and records about its business activities. 

If you’re currently operating an RIA firm, then we hope you have intimate knowledge of Rule 204-2 already, but if you’re exploring independence or just need a quick refresh, here’s what you need to know:

• Rule 204-2 states that all RIA firms must maintain and preserve their required books and records for no less than five years.
• Those records must be easily accessible.
• For the first two years, they must be kept in an appropriate office of the investment adviser.

• Meet books and records compliance requirement.
• Protect your firm. 
• Analyze your content over time.

Social media use by advisers triggers the requirement to retain records of all communications, written and oral recordings, posts, media, comments, and all content, as it is updated on the adviser's social media pages. Record-keeping has always been an important task for RIA firms. You and your firm are responsible for maintaining true, accurate, and current records according to SEC Rule 204-2 and similar state rules.

Compliance
All individuals at your registered investment adviser (RIA) firm that send and receive emails are held to the regulatory requirements related to archiving. Per SEC Rule 204-2, client-facing communications, including emails, must be archived.

Data Storage
In addition to ensuring that your firm is compliant with the books and records requirements for investment advisers, this process can be imperative to reducing performance issues with servers. Given that all email services have a limited amount of data storage capabilities, you may find yourself or your team deleting emails that you believe to not needed now but may be needed in the future.

Email archiving, if set up properly, can move data off the server on an intermittent basis to assure that there is enough storage space, while maintaining records. Additionally, retrieving old emails should be an easy task with the right archiving solution.

Data Security
Hackers can access many areas of old records and electronic communication files that are believed to be out of the inbox and safely stored. Deleting emails and filing away in a location out of your inbox are not secure methods. Email archiving solutions can help protect your data from security threats and hackers, preventing permanent loss of email and all attachments in case of a data breach or disaster.

Record Keeping
Even without a cyber-attack or disaster, email archiving is a reliable way to keep your firm’s records up-to-date and organized. Since archiving maintains all data and attachments, your firm will have a record of all communications with a client as well as any important documents that may need to be accessed or reviewed at any time. Email archiving solutions give you the ability to tag and index all emails in an organized manner for easy retrieval and search as well.

Productivity
Manual systems require employees to spend time transferring emails into storage or deleting emails to prevent capacity limits from being reached. Many companies are also familiar with the downtime caused when employees need to involve IT for help with email storage or transfer issues. Automating the archiving process helps to enhance operational efficiencies by making archiving duties simple for your employees, so they can focus on building client relationships.

It is beneficial to your firm to select a system that is user-friendly and has a simple interface. This will help new users get connected to the system in an efficient manner and can simplify the process for the supervisor to access and complete email review duties.