Being up to date with regulatory changes is a major challenge when you’re operating under the jurisdiction of the Financial Industry Regulatory Authority (FINRA). Especially trying to comply with their constantly evolving requirements – take the recent updates to rule 17a-4 for example; they present significant challenges for small broker-dealer firms with limited I.T. budgets or rely on outsourcing their data compliance. That’s why AdvisorVault offers a comprehensive solution providing a one stop option for all your compliance and archiving needs, helping broker-dealer firms meet FINRA’s latest 17a-4 amendments while maintaining compliance — stop counting sheep (and sleep like a baby) — with AdvisorVault’s all in one Consolidated D3P Service.

Understanding Complexities of the New 17a-4(f) Audit-Trail Requirements

These new rule changes will have a huge affect on the third-party record-keeping services you choose, and the requirements related to timely production of your critical records. The compliance date for broker-dealers is May 3, 2023 – meaning this rule is already in effect. A big addition to Rule 17a-4 is the Audit-Trail Requirement, which can be demanding for small firms without an in-house IT team. This new rule mandates the maintenance of a complete and time-stamped audit trail that includes modifications, deletions, creation dates, identity information, and other relevant details. The complexity and scope of this requirement can feel overwhelming for many smaller FINRA firms.

AdvisorVault’s Consolidated D3P Service: Simplifying Compliance

Under the new requirements ; Firms may continue using the WORM approach for some records while utilizing an audit trail for others. The Securities and Exchange Commission (SEC) does not explicitly address this nuance, (surprise..) leaving it open to interpretation. However, the Financial Industry Regulatory Authority (FINRA) states that maintaining WORM for certain records and using an audit trail for others is permissible.

AdvisorVault’s Consolidated D3P service cover you in either direction, by offering 4 key features to streamline archiving and assist small firms in achieving full compliance with FINRA’s updated rule. These 4 areas are:

  • 1. Retention Format: AdvisorVault’s service allows firms to choose between the legacy WORM approach and the audit trail alternative. This flexibility enables firms to maintain WORM for some records while utilizing an audit trail for others, as allowed by the amended rule.
  • 2. Verification: Under the new rule, firms are required to automatically verify the accuracy and completeness of their recording process. This ensures that the records are reliable and meet the requirements set forth by FINRA. The Consolidated D3P service simplifies this verification process, providing small firms with peace of mind.

  • 3. Download and Transfer: Firms utilizing AdvisorVault’s service can easily download and transfer records and audit trails in both human-readable and usable electronic formats. This feature ensures that firms can readily access and share information when needed, facilitating compliance with recordkeeping requirements.

  • 4. Backup/ Redundant RecordKeeping System: Our solution not only caters to WORM compliance but also provides a backup electronic recordkeeping system to safeguard your data. This redundancy ensures that your records remain accessible to regulators even if your primary system faces disruptions or malfunctions.

Don’t Leave Holes in Your Compliance


Urgent Action is Required To Ensure Seamless Compliance.

Compliance with these updated requirements for broker-dealers is not an option, but a time-sensitive imperative. Firms must act swiftly to ensure adherence to the new rules while mitigating compliance challenges. AdvisorVault’s Consolidated D3P service provides comprehensive solutions to support both WORM and audit trail approaches, helping firms seamlessly transition and maintain compliance with confidence.

The new requirement emphasizes the need for firms to verify the accuracy and completeness of their recording process. While the previous rule focused on verifying the quality of records, the updated rule shifts the focus to ensuring the completeness of capturing original records in the electronic recordkeeping system.

Remember, the compliance date for broker-dealers is already in effect—May 3, 2023. Delaying compliance efforts may expose your firm to regulatory scrutiny and potential penalties. Act now to safeguard your firm’s reputation, protect investor interests, and ensure seamless compliance with the amended rule.

Backup Your Archives for Peace of Mind

Back Up For Continuity:

Maintaining backup and redundant recordkeeping systems is essential for ensuring continuity and reliability in the event of disruptions or malfunctions. WORM compliance requires broker-dealers to store duplicate copies of records separately from the original. This requirement guarantees that regulators can access and examine a firm’s records even if the primary electronic recordkeeping system experiences issues.

Streamline Your Company Compliance:

AdvisorVault’s Consolidated D3P service simplifies the complex landscape of FINRA compliance for small firms. By outsourcing their data compliance needs to AdvisorVault, small firms can focus on more important aspects of their business, such as generating revenue and serving their clients. The AdvisorVault team provides dedicated support and assistance throughout the compliance journey, ensuring that small firms have the guidance they need to meet regulatory requirements.


Update Your Compliance With Advisorvault

Take your compliance to the next level with AdvisorVault’s support and expertise. By leveraging the Consolidated D3P service, small firms can ensure they meet FINRA’s 17a-4 Amendments without the burden of managing complex data compliance requirements in-house.

Don’t let the complexities of regulatory changes overwhelm your small firm. Let AdvisorVault’s Consolidated D3P service provide the peace of mind and assurance you need to focus on what truly matters—growing your business and serving your clients well. Take advantage of this all-in-one solution and streamline your compliance efforts today.

Remember, staying compliant doesn’t have to be a burden when you have the right solutions in place. With AdvisorVault’s Consolidated D3P service, achieving compliance with FINRA’s 17a-4 Amendments becomes simpler and more manageable. Experience the peace of mind and confidence that comes with knowing your data compliance needs are met. Trust AdvisorVault as your partner in compliance excellence.

To find out how your company can update it’s compliance today, visit for your free consultation.

About AdvisorVault

AdvisorVault is a FINRA D3P with a Consolidated 17a-4 Service that is designed to give small firms everything they need to meet today’s data compliance demands. Our turn-key approach performs the archiving, retention, and supervision of electronic records no matter where they are stored – in-house or on the cloud. We provide the required FINRA third party letters with all the needed documentation. For a once-a-month flat fee, it’s the only fully 17a-4 compliant option – Complete data compliance, peace of mind – right out-of-the-box.

Christopher Mancini, Sales
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