# Books And Records > Guide the design and maintenance of recordkeeping programs under SEC Rules 17a-3, 17a-4, and 204-2. Use when the user asks about document retention schedules, how long to keep trade records or customer complaints, WORM storage requirements, email or text message archiving, social media capture, BYOD compliance policies, or electronic storage audit trails. Also trigger when users mention 'we got a… - **Type:** Skill - **Install:** `agentstack add skill-joellewis-finance-skills-books-and-records` - **Verified:** Yes — security-reviewed for prompt injection and unsafe behavior - **Seller:** [JoelLewis](https://agentstack.voostack.com/s/joellewis) - **Installs:** 0 - **Category:** [Communication](https://agentstack.voostack.com/c/communication) - **Latest version:** 0.1.0 - **License:** MIT - **Upstream author:** [JoelLewis](https://github.com/JoelLewis) - **Source:** https://github.com/JoelLewis/finance_skills/tree/main/plugins/compliance/skills/books-and-records ## Install ```sh agentstack add skill-joellewis-finance-skills-books-and-records ``` Requires the [AgentStack CLI](https://agentstack.voostack.com/docs/cli). Works with Claude Code, Cursor, and any MCP-compatible agent. ## About # Books and Records Regulatory status current as of June 2026 — verify effective dates, dollar thresholds, and pending rulemakings against current SEC/FINRA/FinCEN sources before advising. ## Core Concepts ### SEC Rule 17a-3 (Records to be Made) SEC Rule 17a-3 (17 CFR 240.17a-3) specifies the books and records that every registered broker-dealer must create and maintain. These records form the foundation of regulatory oversight, enabling examiners to reconstruct transactions, verify compliance, and protect investors. The principal categories of required records are: - **Blotters (daily records):** Purchase and sale blotters recording every securities transaction (date, time, security, quantity, price, counterparty), cash receipts and disbursements blotters recording all cash flows, and securities received and delivered blotters tracking the movement of securities into and out of the firm. - **General ledger:** A complete general ledger reflecting all assets, liabilities, income, expense, and capital accounts of the broker-dealer. Must be current and maintained in accordance with generally accepted accounting principles. - **Customer account records:** For each customer account, the firm must create and maintain records containing: customer name and tax identification number (SSN or EIN), address, telephone number, date of birth, employment status and name of employer, whether the customer is an associated person of another broker-dealer, investment objectives, annual income and net worth, and the names of persons authorized to transact on the account. The 2003 amendments to Rule 17a-3 (Exchange Act Release No. 34-47910) expanded customer account record requirements to include customer investment profile information — specifically, investment objectives (e.g., capital preservation, income, growth, speculation), investment time horizon, risk tolerance, and other information the firm uses in making recommendations. Firms must also record the date the account was opened and the name of the associated person responsible for the account. - **Order tickets:** A memorandum of each order received for the purchase or sale of securities, showing the terms of the order, the time of entry, the time of execution, the price, and the identity of the associated person who accepted and executed the order. For discretionary orders, the ticket must identify that discretion was exercised. - **Confirmations:** Copies of all trade confirmations sent to customers and received from counterparties pursuant to SEC Rule 10b-10. - **Memoranda of proprietary orders:** Records of each purchase and sale of securities for the firm's proprietary accounts, including the identity of the person who authorized the transaction. - **Customer complaints:** A record of each written customer complaint received by the firm, including the complainant's name, the date the complaint was received, the subject matter, and the firm's response or disposition. FINRA Rule 4513 supplements this requirement with specific complaint recordkeeping standards. - **Associated person employment applications:** Records related to associated persons including Form U4 (Uniform Application for Securities Industry Registration), employment history, disciplinary history, and background investigation results. These records must include the associated person's name, date of birth, address, and the starting date of employment or association with the firm. ### SEC Rule 17a-4 (Records to be Preserved) SEC Rule 17a-4 (17 CFR 240.17a-4) prescribes the retention periods for broker-dealer records. Records are categorized into three tiers based on their required retention period: **Six-year records (Rule 17a-4(a) and (b)):** - Blotters (purchase and sale, cash receipts and disbursements, securities received and delivered) - General ledgers and subsidiary ledgers - Customer account records (including account statements) - Partnership articles, if the broker-dealer is a partnership, and all amendments thereto - Articles of incorporation or charter, if the broker-dealer is a corporation, including bylaws and amendments - Financial statements (trial balances, computations of net capital, reserve formula calculations) - Records of securities positions (stock record, securities record) **Three-year records (Rule 17a-4(b) and (c)):** - Communications — originals of all communications received by the broker-dealer and copies of all communications sent by the broker-dealer relating to its business as such, including inter-office memoranda. This encompasses letters, emails, instant messages, and other forms of business correspondence. - Memoranda of brokerage orders and all other memoranda relating to the firm's business - Written compliance and supervisory procedures (for the three most recent years) - Employment applications and related documentation for associated persons — retained for three years after the individual terminates association with the firm - Written agreements entered into by the broker-dealer (including customer agreements, clearing agreements, and employment contracts) - Reports and questionnaires produced in connection with FINRA examinations and inspections **Lifetime-of-enterprise records (Rule 17a-4(d)):** - Articles of incorporation or organization, charter, minute books, and stock certificate books (or equivalent organizational documents for partnerships, LLCs, or other legal forms) - These records must be preserved for the life of the enterprise and any successor enterprise **First two years — easily accessible:** For all records subject to three-year or six-year retention, the records must be maintained in an easily accessible place during the first two years of the applicable retention period (Rule 17a-4(a), (b)). "Easily accessible" means the firm must be able to produce the records promptly upon regulatory request — they cannot be stored in a manner that requires extensive effort or delay to retrieve during this initial period. **Electronic storage requirements (Rule 17a-4(f)):** Rule 17a-4(f) governs the conditions under which broker-dealers may maintain required records in electronic format. Historically, this rule mandated that electronic records be preserved exclusively in non-rewriteable, non-erasable format — the WORM (Write Once, Read Many) standard. The 2022 SEC amendments to Rule 17a-4(f) (Exchange Act Release No. 34-96034, effective January 3, 2023) modernized these requirements by introducing an alternative to WORM storage. Under the amended rule, electronic records may now be maintained in either: 1. **WORM-compliant storage** — records preserved in a non-rewriteable, non-erasable format that ensures records cannot be altered or deleted; or 2. **Audit-trail alternative** — an electronic recordkeeping system that maintains an audit trail of all record modifications and deletions, creates a complete time-stamped record of changes, and preserves the original and all modified versions. Regardless of which option is chosen, the following requirements apply: - **Index system:** Records must be organized and indexed so that any individual record can be promptly accessed. The index must be stored separately from the records themselves and must be available for immediate production during regulatory examinations. - **Auditable download capability:** The system must be capable of providing a legible, true, and complete copy of any record in the medium and format requested by the examiner. - **Third-party access agent (Rule 17a-4(f)(3)(v) under the pre-2023 rule, now Rule 17a-4(f)(3)(vii)):** The broker-dealer must designate a third-party who has access to the electronic records if the broker-dealer ceases operations. The designated third party is sometimes called a "Designated Examining Authority access agent" or simply the "third-party access agent." The broker-dealer must file a notification with the SEC and its designated examining authority identifying the third party. The third party must file an annual undertaking (letter) with the SEC agreeing to provide access to the records. This requirement ensures continuity of regulatory access to records even if the firm fails. ### Rule 204-2 (Investment Adviser Recordkeeping) SEC Rule 204-2 (17 CFR 275.204-2) under the Investment Advisers Act of 1940 specifies the books and records that SEC-registered investment advisers must make and keep. Investment adviser recordkeeping requirements differ from broker-dealer requirements in scope and emphasis, reflecting the advisory relationship and fiduciary obligations. Required records include: - **Journals and ledgers:** A journal or journals (including cash receipts and disbursements records) and a general ledger (or other record) reflecting all assets, liabilities, reserves, capital, income, and expense accounts. - **Memoranda of orders:** A memorandum of each order given by the investment adviser for the purchase or sale of any security, including the terms of the order, the person who recommended the transaction, the person who placed the order, the date, and the bank, broker-dealer, or other entity through which the order was executed. - **Client records and powers of attorney:** All records showing the identity of each client, including name, address, and advisory agreement. All written powers of attorney and other evidence of authority granted by clients (including trading authorizations and limited powers of attorney). - **Written communications (sent and received):** Originals of all written communications received by the adviser and copies of all written communications sent by the adviser relating to (i) any recommendation made or proposed to be made and any advice given or proposed to be given, (ii) any receipt, disbursement, or delivery of funds or securities, or (iii) the placing or execution of any order for the purchase or sale of any security. This includes emails, letters, instant messages, and any other written or electronic business communication. - **Advertising and performance records:** All written communications that are advertisements (including website content, social media posts, and marketing materials), records substantiating the calculation of performance shown in advertisements and promotional materials, and all supporting documentation for performance claims. Under the SEC Marketing Rule (Rule 206(4)-1, effective November 4, 2022), advisers must retain records of advertisements and all information necessary to demonstrate compliance with the marketing rule's requirements. - **Political contribution records (pay-to-play):** Rule 204-2(a)(18) requires advisers to maintain records of all political contributions made by the adviser or any of its covered associates to officials of government entities, as required under Rule 206(4)-5 (the pay-to-play rule). Records must include the name and title of each contributor, the recipient's name and office, the amount and date of the contribution, and whether the contribution was returned. - **Investment recommendations and supporting documentation:** Records of each investment recommendation made to a client, including the basis for the recommendation, the research or analysis supporting it, and any presentations or proposals provided. Advisers must also retain records of the allocation of investment opportunities among clients (including any trade allocation policies and documentation of how allocations were made in practice). - **Code of ethics records:** The adviser's code of ethics, records of personal securities transactions of access persons, and records of any violations of the code and actions taken. **Retention period:** Most records required under Rule 204-2 must be retained for five years from the end of the fiscal year during which the last entry was made or the record was created. During the first two years of the five-year period, records must be kept in an easily accessible place (i.e., the adviser's principal office or another readily accessible location). **Custody-related records:** Investment advisers that have custody of client assets must maintain additional records per Rule 206(4)-2 (the custody rule), including records of all client funds and securities over which the adviser has custody, a journal showing all purchases, sales, receipts, and deliveries of securities and funds for such accounts, and copies of all account statements delivered to clients. ### FINRA Recordkeeping Requirements FINRA member firms are subject to FINRA-specific recordkeeping obligations that supplement and reinforce the SEC requirements under Rules 17a-3 and 17a-4. **FINRA Rule 4511 (General Requirements):** FINRA Rule 4511 requires each member firm to make and preserve books and records as required under the FINRA rules, the Securities Exchange Act of 1934, and the applicable SEC rules (i.e., Rules 17a-3 and 17a-4). Rule 4511 also requires that all books and records be maintained in a format and medium that comply with Rule 17a-4. This means FINRA firms must meet the electronic storage, index, and accessibility requirements of Rule 17a-4(f) for all records — including FINRA-specific records not explicitly addressed by the SEC rules. **FINRA Rule 3110 (Supervision) — Recordkeeping Implications:** FINRA Rule 3110 generates significant recordkeeping obligations through its supervision requirements: - **Written Supervisory Procedures (WSPs):** The firm's current WSPs and all prior versions within the retention period must be maintained. - **Exception reports:** Output from automated surveillance and exception reporting systems, together with documentation of supervisory review and disposition of each flagged item, must be retained. - **Branch office inspection reports:** Reports from annual inspections of OSJ (Office of Supervisory Jurisdiction) locations and periodic inspections of non-OSJ branch offices, including findings and remediation actions. - **Complaint logs:** A log of all customer complaints received by the firm, cross-referenced to the underlying complaint records and the firm's response. - **Supervisory review documentation:** Evidence that supervisory principals reviewed correspondence (including electronic communications), customer account activity, trade blotters, and exception reports. This documentation must show the reviewer's identity, the date of review, and any actions taken. - **Annual compliance meeting records:** Documentation of the firm's annual compliance meeting required under FINRA Rule 3110(a)(7), including attendees and topics covered. **FINRA Rule 4513 (Records of Written Customer Complaints):** Requires a separate file of all written customer complaints, indexed by complaint type and by associated person. The complaint record must include the complainant's name, date received, associated person identified, nature of the complaint, and disposition. These records are retained for at least four years. ### Electronic Communications Archiving SEC and FINRA rules require broker-dealers and investment advisers to capture, retain, and supervise all business-related electronic communications. The regulatory framework does not distinguish between communication platforms — the obligation applies uniformly regardless of the technology used. **Scope of covered communications:** The requirement extends to all written business communications, including email, instant messaging (Bloomberg chat, Reuters Eikon messaging, proprietary IM systems), text messages (SMS and messaging apps such as iMessage and WhatsApp), collaboration platforms (Microsoft Teams, Slack, Zoom chat), and any other electronic medium used to communicate about firm business. **Key regulatory guidance:** - **FINRA Regulatory Notice 07-59** — Addressed the supervision of electronic communications, emphasizing that firms must establish systems and procedures to review electronic communications for evidence of sales practice violations, customer complaints, and other compliance concerns. … ## Source & license This open-source skill is cataloged on AgentStack and links to its original source — we do not rehost the code. - **Author:** [JoelLewis](https://github.com/JoelLewis) - **Source:** [JoelLewis/finance_skills](https://github.com/JoelLewis/finance_skills) - **License:** MIT Install and usage instructions live in the source repository linked above. ## Pricing - **Free** — Free ## Security capabilities Automated source analysis of v0.1.0 — what this tool can access: - **Network access:** no - **Filesystem access:** no - **Shell / process execution:** no - **Environment & secrets:** no - **Dynamic code execution:** no *"Yes" means the capability is present in the source — more access means more to trust, not that it is unsafe.* ## Versions - **0.1.0** — security scan: passed — Imported from the upstream source. ## Links - Listing page: https://agentstack.voostack.com/l/skill-joellewis-finance-skills-books-and-records - Seller: https://agentstack.voostack.com/s/joellewis - Browse the marketplace: https://agentstack.voostack.com/browse --- Listed on AgentStack — the marketplace for AI agent skills and MCP servers. 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