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CurrentClient Compliance Documentation

Meeting SEC/FINRA Communication Retention & Supervision Rules.

1. Overview#

This document describes how CurrentClient meets SEC Rule 17a-4, the Investment Advisers Act of 1940, and FINRA Rules 3110 & 4511 recordkeeping and supervision requirements.

Audience: Compliance officers, auditors, and regulators reviewing the use of CurrentClient for compliant communications archiving.

2. Record Capture#

CurrentClient automatically captures:

  • Text Messages (SMS/MMS) – Full message content including media files.
  • Metadata – Sender/recipient, date/time, message ID, delivery status.

Records are captured in real time and stored immediately in a secure archive.

3. Retention & Regulatory Compliance#

  • Retained for a minimum of 5 years; first 2 years instantly retrievable.
  • Stored in AWS S3 with object versioning enabled.
  • Original records cannot be overwritten — edits/deletions create a new immutable version while retaining the original.
  • Version history includes timestamps, user/process changes, and access to prior versions.
  • Aligns with SEC Rule 17a-4(f) 2022 amendments allowing version-controlled, audit-capable systems.

4. Integrity & Security#

  • Version Control – Preserves all historical versions of a record.
  • Audit Logging – Tracks access, exports, and modifications.
  • Encryption – TLS 1.2+ in transit, AES-256 at rest.
  • Access Controls – Role-based permissions to restrict who can view, search, or export records.

5. Supervision & Review Tools#

  • Searchable Archive – Search by client, keyword, date range, or record type.

  • Supervision Workflows – CurrentClient supports supervision by:

    • Sending all captured messaging data to the firm’s chosen third-party archiving system for review, or
    • Co-locating all captured messaging data into the firm’s existing email archive so their current supervision workflows apply.

  • Review Logs – If the firm uses CurrentClient’s direct archive export, activity logs record when reviews occur and by whom.

6. Retrieval for Regulatory Requests#

  • Export Capabilities – CSV, PDF, and media formats for regulators.
  • Time-Stamped Certification – Confirms record authenticity.
  • No Gaps in Records – Continuous capture with no user-side deletion.

7. Advisor Responsibilities#

Advisors must:

  • Maintain a written communications retention and supervision policy.
  • Periodically review communications for compliance issues.
  • Ensure all business messaging takes place through CurrentClient or other approved channels.

8. CurrentClient Commitment#

CurrentClient is committed to:

  • Providing advisors with a compliant, secure messaging archive.
  • Maintaining system compliance with SEC/FINRA rules.
  • Supporting retrieval requests during regulatory audits.

Related Articles#

CurrentClient Compliance Documentation
CurrentClient Compliance Documentation