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Savithri Satyavani Nanduri
Savithri Satyavani Nanduri

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5 Common Mistakes That Lead to FINRA 17a-4 Violations (And How to Avoid Them)

What is FINRA Rule 17a-4?
It’s a U.S. regulation that requires broker-dealers to:

Store data in WORM (Write Once, Read Many) format

Retain records for up to 6 years or longer

Ensure all records are searchable, indexed, and auditable

This isn’t about backups — it’s about regulatory-grade immutability and provable governance.

Mistake #1: Not Using Certified WORM Storage
🧨 Many assume traditional backups or cloud drives meet WORM standards.
⚠️ Spoiler: They usually don’t.

How to fix it:

Use certified WORM solutions like Amazon S3 with Object Lock, or Solix Enterprise Archiving which offers WORM compliance out of the box.

Always validate your storage configuration.

❌ Mistake #2: Data Scattered Across Legacy Systems
🗂️ Finance teams often store records across old Oracle DBs, file shares, or outdated email servers.

Problem: Can’t locate everything during an audit = non-compliance.

How to fix it:

Centralize data from both structured (databases) and unstructured (emails, PDFs) sources into one compliant archive.

Ensure records are indexed by metadata (date, type, user ID, etc.)

❌ Mistake #3: No Chain-of-Custody or Audit Trails
🔍 Auditors want proof of who accessed what, and when.

Problem: Most legacy systems don’t track this—or store logs separately.

How to fix it:

Use platforms that generate immutable audit trails

Set up automated reports for regulators or internal compliance teams

❌ Mistake #4: Manual Retention Tracking
🗓️ FINRA mandates specific retention periods by document type.

Problem: Teams rely on spreadsheets and manual tagging = risk of error.

How to fix it:

Automate retention policies based on content type, regulation, and jurisdiction using policy-driven archiving

❌ Mistake #5: Assuming Cloud SaaS Tools Are Automatically Compliant
☁️ Services like Office 365 or Google Drive are great—but compliance is your responsibility, not theirs.

How to fix it:

Offload relevant SaaS data into a FINRA-compliant archive

Apply WORM, retention, and audit layers on top

What to Look for in a FINRA-Compliant Archive

Feature Why It Matters
🔐 WORM Storage Prevents tampering or deletion
🧠 Policy Automation Reduces risk of human error
🔍 Full-Text Search + Indexing Fast access during audits
📜 Immutable Audit Trails Satisfies chain-of-custody requirements
📂 Support for Mixed Data Handles emails, PDFs, logs, databases, etc.

Bonus: Free FINRA Compliance Checklist
Want to assess your firm’s current risk posture?

Grab our internal checklist used for FINRA audits:

✅ WORM storage validation

✅ Legal hold enforcement

✅ Chain-of-custody logging

✅ Search & recovery simulation

👉 Download it here

Final Thoughts
Compliance isn’t just about ticking a box — it’s about building trust and resilience.

Avoid these common mistakes, modernize your data archiving, and your next FINRA audit will be fast, painless, and fully traceable.

Want help archiving legacy records, emails, or trade data?
Learn more: enterprise archiving

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