🧾 Map 17Ad-7(d) six-year cancelled certificate records to custody and evidence workflows

[JFWooten4]

17 CFR § 240.17Ad-7(d) requires 17Ad-6(c) records to be kept for at least six years, with the first six months in an easily accessible place.

This issue tracks cancelled registered bonds, debentures, shares, warrants, rights, other registered evidence of indebtedness, other certificates of ownership, and accompanying documentation.

Covered content

17 CFR § 240.17Ad-6(c)

Every registered transfer agent which, under the terms of its agency, maintains securityholder records for an issue shall, with respect to such issue, retain each cancelled registered bond, debenture, share, warrant or right, other registered evidence of indebtedness, or other certificate of ownership and all accompanying documentation, except legal papers returned to the presentor.

Implementation notes

This is the longest ordinary 17Ad-7 bucket in this set and should be treated as a custody/evidence problem, not just a document-storage problem.

For TAD workflows, we should be clear whether a cancelled certificate or equivalent evidence exists, whether the record is paper, scanned, digital-native, protocol-derived, or replaced by another authoritative record. The implementation needs to show how accompanying documentation is retained, while excluding legal papers returned to the presentor.

Task list

• Identify whether any covered cancelled certificate or equivalent evidence exists in current workflows.
• Map cancelled share, warrant, right, debt, or other ownership evidence records to storage locations.
• Map accompanying documentation to the same retention pathway.
• Separate retained documentation from legal papers returned to the presentor.
• Confirm where the first-six-month easily accessible copy lives.
• Confirm the six-year retention path.
• Identify any protocol-native equivalent records that need explanatory documentation.