Learn from the mistakes of others (and don’t repeat them!)

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In 2013, Barclays Investment Bank ended what should have been a pretty good year by taking a pretty big hit – a $3.57 million fine levied by The Financial Industry Regulatory (FINRA) for failing to preserve its electronic documents and records, as mandated, over a ten year period.

Between 2002 and 2012 (and possibly even earlier), Barclays improperly archived its electronic records and failed to preserve them in the mandated Write-Once-Read-Many (WORM) format. Barclays also had improperly retained attachments to over three million Bloomberg emails between 2007 as well as materials from instant messages and other electronic correspondence that FINRA deemed relevant to Barclays’ business practices and day-to-day operations.

Worse yet, according to FINRA,this failure to properly archive documents and attachments made it nearly impossible for the company to adequately “respond to requests for electronic communications in regulatory and civil matters.” A real can of worms…

Where did Barclays really go wrong? One FINRA executive indicated that the lack of compliance was a direct result of Barclays’ failure to implement and maintain a quality electronic archive and storage system for its emails and other digital communications. Such a system would have allowed the company to establish compliance with FINRA, and with the Securities and Exchange Commission, and the National Association of Securities Dealers. But Barclays didn’t, so it couldn’t retrieve electronic documentation requested by regulating agencies or determine whether its electronic records had been preserved in their original, unaltered condition.

Learn from Barclays’ misfortune. Form an alliance with a trusted technology partner (like us) to ensure your files are compliant and readily accessible. Ask about Patrina’s comprehensive regulatory archival and compliance solutions specifically designed for Broker/Dealers, RIAs, and FCMs. Or…you could do it all yourself…

Let’s talk (212- 233-1155).

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