is the SYSTEM compliant?

Yes. All records are preserved in an exclusive non-rewritable, non-erasable or “WORM” (Write Once Read Many) format. All documents are imaged properly and the optical copy is legible. The quality and accuracy of the optical storage recording process is verified and the duplicate copy contains all information as it was originally preserved. The original and duplicate are serialized and the information is placed on disks and permanently time-stamped.

• Records are arranged, indexed and filed in such a manner as to permit the immediate location of any particular record requested. The capacity to download indexes and records preserved on optical disk to paper, microfilm or microfiche.

• Facilities are available at all times for immediate, easily readable projection of optical disks and indexes.

• All information needed to download records and indexes stored on optical disks is available to the SEC, NASD, individual states and the broker/dealer personnel to review at their request.

• An automatic audit program is in place to provide accountability regarding access to records maintained and any changes made to every original and duplicate optical disk.

• A duplicate copy of each optical disk and index used to store required records for the required time period are stored in an off-site location. The off-site location is able to retrieve all information in the same manner.

Indexing
The indexing system creates an organized document filing system and makes future retrieval simple and efficient. A good indexing system will make existing procedures and systems more effective. 

Retrieval
The retrieval system uses information about the documents, including index and text, to find images stored in the system. A good retrieval system will make finding the right documents fast and easy. 

Access
Document viewing should be readily available to those who need it, with the flexibility to control access to the system. A good access system will make documents viewable to authorized personnel, whether in the office, at different locations, or over the Internet

KEY COMPONENTS

Currently, there are eight components to consider when going paperless. Though most paperless environments usually only contain three, eight is essential for a truly efficient and compliant paperless environment.

• Hardware (scanner, server, etc.)

• Document Imaging Software

• Document Management Software

• Rights & Access Software
  Workflow Management Software and

• Procedures

• Optical Recognition Software

• Access and Recovery of Data (web-based preferred)

• Disaster Recovery Procedures