Broadridge Financial Solutions Inc. Message Board

Next, the broker-dealer must make a representation, or obtain one from a storage vendor or other third party “with appropriate expertise,” that the broker-dealer’s selected storage media meets the conditions set forth in Rule 17a-4(f).

The broker-dealer or third party expert must attest that the electronic storage media will: (1) preserve the records exclusively in a non-rewriteable, non-erasable format (subsequent interpretive guidance from the SEC states that media itself need not be physically rewriteable and non-erasable, and that “non-rewriteable, non-erasable” can be achieved using “integrated hardware and software control codes”); (2) verify automatically the quality and accuracy of the storage media recording process; (3) serialize the original and, if applicable, duplicate units of storage media, and time-date for the required period of retention the information placed on such electronic storage media; and (4) have the capacity to readily download indexes and records preserved on the electronic storage media to “any medium acceptable” under Rule 17a-4(f) as required by the SEC or the self-regulatory organizations of which the broker-dealer is a member.

In addition, every broker-dealer exclusively using electronic storage media for any of its record preservation must make arrangements with at least one third party who has access, and the ability, to download information from the broker-dealer’s electronic storage media to “any medium acceptable” under Rule 17a-4. The third party downloading service provider, which may or may not be the same service-provider that is storing the electronic records, must file with the SEC and the broker-dealer’s DEA two undertakings with respect to the electronically maintained records.

The service provider must undertake to: (1) “furnish promptly” to the SEC or its designee “upon reasonable request,” such information as “is deemed necessary” by the SEC or its designee by downloading the information from the broker-dealer's

Keeping Broker Records In The Cloud
Michael Kurzer
Voices, January 20, 2011
Broker-dealers caught unaware have paid millions in fines for failure to comply with the Securities and Exchange Commission’s requirements to preserve books and records.

For instance, a large brokerage firm in 2006 agreed to pay a $15 million settlement for allegedly failing to produce e-mails and electronic records in a timely manner during the course of two separate SEC investigations. In 2009, the brokerage arm of a large commercial bank agreed to pay several million dollars in fines for, among other things, failure to retain electronic records pertaining to its business, following hearings before the New York Stock Exchange and the Financial Industry Regulatory Authority.

Now comes computing in the cloud, which should save firms big bucks by placing their applications and data on servers and systems maintained by other parties. Already, many broker-dealers take advantage of third party service providers in the “cloud” to archive e-mail, text messages, and other electronic documents, including financial transaction data, trade confirmations, and net capital records.

Kurzer

Fortunately, outsourcing of record-keeping is an area for which the SEC provides reasonably clear guidance, principally through Rule 17a-4(f), under the Securities Exchange Act of 1934.

Prior to relying on a third party for electronic record-keeping, a broker-dealer is required to notify the SEC and a designated examining authority (“DEA”) such as FINRA of its intention to do so. Under Rule 15b3-1, the broker-dealer must amend its Form BD to identify to the SEC and self-regulatory organizations of which it is a member, like FINRA, “any arrangements” with third parties who maintain the broker-dealer’s books or records. FINRA has adopted both NASD Rule 3110 and NYSE Rule 440, which reiterate the need to preserve books and records in compliance with Rule 17a-4.

Next, the broker-dealer must make a representation, or

In response to the guy in J.S. who knows what a sham the survey is I would have to agree with you. Management DOES NOT CARE about the workers. They also allow favorites to get away with unspeakables but punish others for the slightest thing. VP's think they can do whatever they want and apparently they can. HR is useless otherwise they would not allow the VP of inserting to take his title literally. Poor girl. Complaints about managers that spew "Now that you're here hop up on the desk and entertain us" go unpunished (actually the man was promoted). Maybe they have pictures as well which is the rumor and a qoute from the HR man himself. Senior leaders who promote systems that don't work so they can say, i met my MBO, and force others to work 7 days a week, often 14 hours a day is commonplace. Apparently certain bonus payouts are based on meeting objectives and are not discretionary. Lawsuit must have some validity!! Great place to work? Forced to work on Saturdays (told if you don't HE WILL KNOW and you will be put on his S..T LIST). Does this really sound like a great place to work. When the team put in place to protect associates is too scared for their own job or under strict orders to protect "the elite - the ones with the pictures" where does that leave the abused worker. Ask the entire group of people that went to HR with complaints about the QA group. Best Place to Work? Really? Taking staff out for dinner at your country club so you can meet your annual obligation? I wonder how many take a write-off on their personal tax returns even though they get reimbursed for the dinners and parties!! Great place to work. 50-100 get to go on a great trip every year yet the company cut the company picnic which was enjoyed by hundreds,. I guess they don't really care about the workers, only the elite. Salesman abuse their expenses and have no accountability. $200 bottles of wine without a client to be seen. Let's do a white and a red. WTH, NOT MY MOENY

FINRA Disciplinary Actions Online

Disciplinary Actions Online Home | Search Help

Searched for Broadridge and got five hits!!!

Go directly to SEC. They are extremely helpful and eager to talk!!!

Assistance and information from a whistleblower who knows of possible securities law violations can be among the most powerful weapons in the law enforcement arsenal of the Securities and Exchange Commission. Through their knowledge of the circumstances and individuals involved, whistleblowers can help the Commission identify possible fraud and other violations much earlier than might otherwise have been possible. That allows the Commission to minimize the harm to investors, better preserve the integrity of the United States' capital markets, and more swiftly hold accountable those responsible for unlawful conduct.

Finra is another great place to report things.

The Commission is authorized by Congress to provide monetary awards to eligible individuals who come forward with high-quality original information that leads to a Commission enforcement action in which over $1,000,000 in sanctions is ordered. The range for awards is between 10% and 30% of the ney collected.

The Office of the Whistleblower was established to administer the SEC's whistleblower program. We greatly appreciate your interest, and we hope that this website answers any questions you may have.
We understand that the decision to come forward with information about securities fraud or other wrongdoing is not one taken lightly, and we are here to answer any questions you may have. You can reach the Office of the Whistleblower at ******* (202) 551-4790 ******.

Unmailed margin letters, possible sell-outs, billing clients for services not performed, losing valuable documents. OMG. The list goes on and on.

I hear ET has a new person in charge (not a BR fan) and its probably a matter of time before they jump. Cost consessions to make them stay will only keep them for so long. Big consessions from what I hear.

Who is $$$liable$$$$ (the provider or brokerage firm) for non-compliance!!

Sentiment: Strong Sell

Great website wwx.secwhistlebloweradvocate.comx/program/monetary-sanctions-awards

For the first time, there are meaningful monetary incentives for individuals to come forward and report possible securities violations.
Monetary Sanctions and Awards
For the first time, there are meaningful monetary incentives for individuals to come forward and report possible securities violations. Although federal programs that provide monetary awards for whistleblowers have been around since the Civil War, for the first time, the Dodd-Frank Wall Street Reform and Consumer Protection Act authorized the payment of monetary awards to individuals who report violations of the federal securities laws to the SEC. Under the Act, the SEC is required to pay eligible whistleblowers 10-30% of the monetary sanctions collected as a result of a successful SEC enforcement action or actions in which the sanctions exceed $1 million. Monetary awards may be substantial. To put this in context, consider that in Fiscal Year 2011 alone, the SEC secured $2.8 billion in monetary sanctions. In several cases, sanctions exceeded $100 million. Significantly, these figures do not include the monetary sanctions collected in related enforcement actions by other regulatory and law enforcement organizations, such as the Department of Justice.

To ensure that adequate funds are available to pay whistleblower awards, Congress has established a replenishing Investor Protection Fund, which at the close of Fiscal Year 2011 had a balance in excess of **** $450 million ****

BR Shorts: Read, weep, thank me later... bit^ly/YGnc6Q (change ^ to a period)

Pattern continues. Stock price going nowhere. Management that knowingly supports managers that cheat on expense reports, cheat on productivty reports, lie to corporate auditors (make staff create policy documents with phoney dates to make it appear like they existed for months before they were written), make staff create proof that they followed these policies (the ones that did not exist) so he can pass the corporate audit, destroy reports that make him look bad makes your wonder if the claims about pictures are true. HR is so guilty for allowing all of the complaints to go unpunished. Exit interviews don't lie. Anyone see the 60 Minute segment about the teenager in Ohio who got abused and the abusers friends sat back and watched. Now they are getting in trouble for standing idle while the poor girl was abused. Integrity ?? Employee of Choice?? Service Profit Chain?? Why have an HR if they are unempowered or under strict orders to "protect ....! Ethics Hotline (confidential) is also a sham...

Upward move is nice to see but is must likely the company buying back shares (hide their cash so they don't get bought). I know alot of ex workers that tell me horor stories about the company. The Yahoo fiasco is the tip of the iceberg and was only disclosed because they got caught. Orders for material that go unfilled (but client billed? Compliance?). TRow/MasMus management left or threaten to leave all the time. Management told that the FINAL voting numbers sent to FS were incorrect (outstanding shares were mistakenly counted twice in some cases) and they choose to "keep it to themselves". Man, the % of shares voted F/A/A were wrong and they keep quiet. Man, if FS knew that their data was being viewed and manipulated in India. The proxy system is so old and does not satisfy the users needs so offshore teams are asked to manipulate PRODUCTION DATA so the users can give the clients what they need. NO QA/QC. The voting system is a sham. Your vote does not always count since they have no way of knowing where the overvote stems from so they could be throwing away your vote and counting a non-shareholders vote. Reconcilliation system is from the dark ages. SLAs are constantly missed buy "tricks are played to avoid penalties". When you question management they respond (analogy - We mailed the documents on time. But the PO doesn't pickup from that box since 2010. So what, our SLA only states that we must have in a mailbox....) D/R committed to in contracts did not exist for 4-5 years after the contract was signed. No integrity by managements and will do anything to make their numbers. With all this they still can't move the needles. Cheater(s) are rewarded handsomely at the company..