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Run: Books and Records Retention Compliance Checklist

Use this checklist to verify that client agreements, communications, and transaction records are retained, indexed, and retrievable for SEC examination readi...

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Inspection Setup and Scope

Inspection period and scope documented

Record the date range, entity, office, and systems included in the review.

Record categories selected for testing

Select the record types included in the sample.

Note (optional)

Retention policy and schedule available to inspector critical (required)

Confirm the current retention policy, schedule, or written supervisory procedure is available for review.

Yes No N/A

Retention Period Compliance

Client agreements retained for required period critical (required)

Confirm client agreements and amendments are retained for at least five years, with the first two years readily accessible.

Yes No N/A

Communications retained for required period critical (required)

Confirm business-related communications subject to retention are preserved for the required period and are searchable or retrievable.

Yes No N/A

Transaction and trade records retained for required period critical (required)

Confirm transaction records, confirmations, and related support are retained for at least five years and are available for the first two years without delay.

Yes No N/A

Accessibility, Indexing, and Retrieval

First two years of records readily accessible critical (required)

Verify records required to be readily accessible can be produced promptly without manual reconstruction.

Yes No N/A

Records indexed by client, account, date, or document type

Confirm the archive supports logical indexing and retrieval by common examination fields.

Yes No N/A

Sample retrieval time

Measure the time required to retrieve a requested record from the archive.

Note (optional)

Missing or unretrievable records identified

Document any records that could not be located, produced, or verified during the sample.

Record Integrity and Preservation

Records preserved in original or compliant electronic form critical (required)

Confirm records are maintained in a manner that preserves content, context, and evidentiary integrity.

Yes No N/A

Audit trail or version history available for electronic records

Verify the system maintains audit logs, version history, or equivalent controls for record changes.

Yes No N/A

Backup and disaster recovery controls protect retained records critical (required)

Confirm retained records are included in backup, recovery, and business continuity controls.

Yes No N/A

Supervision, Exceptions, and Corrective Action

Retention exceptions or gaps documented

Describe any missing records, late deletions, system failures, or retention exceptions identified during testing.

Corrective action assigned for deficiencies critical (required)

Confirm each deficiency has an owner, due date, and remediation plan.

Yes No N/A

Examination readiness confirmed critical (required)

Confirm the firm can produce requested records in a timely manner and explain retention controls during an SEC examination.

Yes No N/A

Inspector Sign-Off

Overall inspection result

Select the final outcome of the inspection.

Note (optional)

Inspector comments and summary

Summarize key findings, material deficiencies, and follow-up actions.

Inspector signature critical (required)

Inspector sign-off confirming the inspection was completed accurately.

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