🗂️ Map 17Ad-7(b) retention records to monthly processing and notice records

[JFWooten4]

17 CFR § 240.17Ad-7(b) requires the listed 17Ad-6 record categories to be kept for at least two years, with the first year in an easily accessible place.

This issue tracks the monthly processing, turnaround, outside registrar, performance calculation, written notice, and inquiry exception records that need to be tied back to actual TAD operating workflows and compliance proofs.

Covered content

17 CFR § 240.17Ad-6(a)(2)

A log, tally, journal, schedule or other record showing for each month:

(i) The number of routine items received;

(ii) The number of routine items received during the month that were turned around within three business days of receipt;

(iii) The number of routine items received during the month that were not turned around within three business days of receipt;

(iv) The number of non-routine items received during the month;

(v) The number of non-routine items received during the month that were turned around;

(vi) The number of routine items that, as of the close of business on the last business day of each month, have been in such registered transfer agent's possession for more than four business days, aged in increments of one business day (beginning on the fifth business day); and

(vii) The number of non-routine items in such registered transfer agent's possession as of the close of business on the last business day of each month;

17 CFR § 240.17Ad-6(a)(3)(ii)

A log, tally, journal, schedule or other record showing for each month:

(A) The number of items received;

(B) The number of items processed within the time required by § 240.17Ad-2(b); and

(C) The number of items not processed within the time required by § 240.17Ad-2(b);

17 CFR § 240.17Ad-6(a)(4)

A record of calculations demonstrating the registered transfer agent's monitoring of its performance under § 240.17Ad-2 (a) and (b);

17 CFR § 240.17Ad-6(a)(5)

A copy of any written notice filed pursuant to § 240.17Ad-2;

17 CFR § 240.17Ad-6(a)(7)

A log, journal, schedule or other record showing the number of inquiries subject to § 240.17Ad-5 (a), (b), (c) and (d) received during each month but not responded to within the required time frames and the number of such inquiries pending as of the close of business on the last business day of each month;

Implementation notes

This bucket is mostly monthly operating evidence. It should connect the transfer-agent processing dashboard, any CRON or scheduled reporting jobs, any manual review process, and any written 17Ad-2 notices into one retention story.

The key practical question is not just whether the data exists, but whether we can prove the monthly counts, calculations, exceptions, and notices from stable records retained in an easily accessible place for the first year.

Task list

• Map 17Ad-6(a)(2) to monthly routine and non-routine item reporting.
• Map 17Ad-6(a)(3)(ii) to monthly outside registrar reporting, if applicable.
• Map 17Ad-6(a)(4) to 17Ad-2 performance calculations.
• Map 17Ad-6(a)(5) to any filed 17Ad-2 notices.
• Map 17Ad-6(a)(7) to inquiry exception and pending inquiry records.
• Identify which records are generated by CRON/scheduled jobs.
• Confirm where the first-year easily accessible copy lives.