Help for Banks & Financial Services Firms
How to Comply With SEC and NASD Rules for
Broker / Dealer Email
How to Manage Electronic Document Retention & Deletion
(The following are stored in Adobe PDF file format)
Articles, Workshop Materials, Regulations, Supporting Documents, Success Stories...
Guidelines for Electronic Document Retention and Deletion Policies ("Help Your Clients Deal With Document Retention and Deletion", Journal of Internet Law, April, 2004, by Tom Ingram)
Sarbanes-Oxley Section 802, Section 804 (penalties for document destruction, management and third party attestation)
SEC 17a-4 (retaining electronic communications, email)
SEC 17a-3 (retaining other records)
SEC 17f-2 (retaining fingerprint records)
NASD 3010 (supervisory system requirements)
NASD 3110 (types of records and audit trails required to be kept)
Investment Advisers Act of 1940 (SEC 204, 203, 206, Summary, Index)
Workshop: Electronic Document Retention and Deletion Workshop
Workshop: Email Compliance for Broker / Dealers
Workshop: Email and Electronic Document Compliance for Investment Advisers
Computer Projects Fail 50% - 70% of the Time - Why?
Impact of Failed Computer Projects On Earnings
Summary Table Showing Millions Wasted on Bad Computer Projects (Total Cost of Not Doing Things Right the First Time)
Understanding How To Improve Computer Project Outcomes
Sample Report Identifying How Specific Regulations Will Be Complied With
Sample Action Items, Issues and Minutes Log (password required)
Sample Requirements Log Leading to Detailed Request For Proposal
Sample RFP (Request for Proposal / Request for Information) (requires password)
Work Plan for Developing and Implementing a Document Retention and Deletion Policy (requires password)
Work Plan for Defining, Selecting and Implementing an SEC/NASD Compliant Email System for Registered Reps (requires password)
SUCCESS STORIES...
Newsletter 21 Managing Email and Electronic Documents Helps Client Win $5 Million Fraud Settlement
Success Story 11 West Coast Bank becomes SEC 17a-4f Compliant in 8 Weeks!
Newsletter 14 30 Percent Labor Savings and Improved Customer Service!
Newsletter 2 How an Accounting Department Saved $450,000/year and Improved Service
HORROR STORIES...
Horror Stories General (General summary of email and document retention and deletion horror stories)
Horror Story 1: Quattrone Convicted on Email Suggesting People "Follow Doc. Retention Policy" (Destroy Documents.)
Horror Story 2: $6,200,000 wasted by major Midwest bank on computer project
Horror Story 3: Associates Financial attempts to develop loan administration system. System completed late and required substantial rework.
Horror Story 4: West Coast Savings and Loan wasted $1,500,000 in attempts to develop system for loan processing and customer service. Had to restart three times with new vendors. Litigation being threatened.
Horror Story 5: Nations Bank wastes $750,000 on consolidated customer information system. Experienced multiyear delays, dismissed Perot Systems and took project in-house.
Horror Story 6: Fidelity Investments wastes $110,000,000 developing system to allow financial trades from home computers. Competitors (arguably) developed same system for 1/10th the cost.
Horror Story 7: MFS Fined $350,000,000 on Email Evidence, Required to Retain Independent Consultant for Oversight.
Client Comments on Results We Have Provided...
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"...The use-cases that you guys re-wrote for us are so much easier to understand than the work done by the original consultant...
"...you helped us sort through the mess and get back on track. The order flow structure you put in place helped us get focused on the right things and bring the team together..."
Richard Heyse, CFO, Visual Reach.Com
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"... You will be greatly missed. Thanks for all your hard work & organizational skills that helped us get the Authenticate-only project going. You did a great job of stepping in quickly and getting things under control..."
M. Lynette Smith, Client Manager, Verizon
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"... our guys tell me that the document production system you helped us with has reduced the labor required by 30%!"
"...we've been burned by consultants before... we appreciate this project coming in as promised and within our budget..."
Alan Little, Technical Sales Manager, Engineered Air Balance, Dallas Office
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"Tom helped us achieve a 25-30% reduction in the Test and Quality Assurance cycle time for our year 2000 efforts."
Shirley Sanger, former Assistant Director of IT, City of Fort Worth
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"We had contracted with you after a series of disappointments in working with technology firms..."
"The technology firms that received [the bid package you created for us] were greatly impressed with the care with which it had been crafted... virtually every detail had been thoroughly thought through and clearly specified."
"You guided us through an incredibly complex undertaking...that resulted in thousands of dollars of saved costs."
"We saved an enormous amount of money - and grief - by working with you. Thanks for your help."
Dick Grote, President, Grote Consulting
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"The project analysis you helped us with was invaluable."
"By looking at our past projects you have helped us understand what we need to work on."
Marc Guy, Assistant City Manager, City of Carrollton
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"Thanks for your work helping us define our new customer on-boarding process. You helped us define a complex work process and gave us a boost in solving these problems ourselves."
"I've never seen an internal IT guy that didn't say, 'I got it!'..."
Clay Curtis, CIO, Crossmark
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Services Offered...
An Overview of Services Offered
