FINRA now allows member firms to use the cloud to store electronic records and emails, however if you are a compliance officer and have done your homework, you have noticed that cloud providers will not act as your designated third party (D3P). Reason being, they can't guarantee data stored with them will be retained for 7 years. In other words, they can't prevent anyone from deleting anything from their cloud account at anytime - a big no-no for regulators. Especially when they show up for the electronic records request during the audit and see huge gaps in your data archive. Therefore, if you are a FINRA firm, such as a broker-dealer, RIA or any other registered firm and want to use the cloud you need to find a D3P that will connect into it and make it 17a-4 compliant.
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