Under SEC Rule 15a-6, foreign broker-dealers are allowed to distribute research reports to U.S. institutional investors providing their work through a “chaperoning broker-dealer.” The SEC Compliance DeskTop now provides a simple and cost-effective platform for managing research report approvals and distribution as well as complying with the retention requirements of SEC Rule 17a-4.
By adopting Rule 15a-6, the SEC provides, among other terms, a mechanism for the distribution of foreign-broker-dealer research reports. However, managing the flow of incoming research reports, supporting the review and approval process and retaining those reports as required by SEC Rule 17a-4 requires a work-flow system which:
- Allows a foreign broker to email a research document to a hosted email address
- Automatically adds the report to an SEC 17a-4 retention library
- Generates an alert to be sent to a principal at the chaperoning broker-dealer
- Allows the principal to review the research report and approve a copy to be moved to an approved SharePoint research library
- Enables clients of the chaperoning broker-dealer to receive alerts and download new research reports into their in-house research systems
- Results in content that can be expire based on retention periods
In partnership with the Law Department Desktop (www.lawdepartmentdesktop.com), 17a-4 has built the SEC Compliance DeskTop using a cloud-based SharePoint hosted at Rackspace®. “We will continue to build more work-flow functionality into the DeskTop,” adds Charles Weeden, Managing Partner of 17a-4, “and in the next release we plan to incorporate compliance review functionality for outside business activities (“OBA Reports”).