📁 Map 17Ad-7(a) retention records to covered 17Ad-6 workflows

[JFWooten4]

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

This issue tracks the specific 17Ad-6 categories that belong in the 17Ad-7(a) retention bucket and should be explained against our actual TAD workflows, intake records, outside registrar touchpoints, written inquiries, and non-routine item determinations.

Covered content

17 CFR § 240.17Ad-6(a)(1)

A receipt, ticket, schedule, log or other record showing the business day each routine item and each non-routine item is (i) received from the presentor and, if applicable, from the outside registrar and (ii) made available to the presentor and, if applicable, to the outside registrar;

17 CFR § 240.17Ad-6(a)(3)(i)

A receipt, ticket, schedule, log or other record showing the date and time:

(A) Each item is (1) received from the presenting transfer agent and (2) made available to the presenting transfer agent;

(B) Each written or oral notice of refusal to perform the registrar function is made available to the presenting transfer agent (and the substance of the notice); and

17 CFR § 240.17Ad-6(a)(6)

Any written inquiry or request, including those not subject to the requirements of § 240.17Ad-5, concerning an item, showing the date received; a copy of any written response to an inquiry or request, showing the date dispatched or mailed to the presentor; if no response to an inquiry or request was made, the date the certificate involved was made available to the presentor; or, in the case of an inquiry or request under § 240.17Ad-5(a) responded to by telephone, a telephone log or memorandum showing the date and substance of any telephone response to the inquiry;

17 CFR § 240.17Ad-6(a)(11)

Any document upon which the transfer agent bases its determination that an item received for transfer was received in connection with a reorganization, tender offer, exchange, redemption, liquidation, conversion or the sale of securities registered pursuant to the Securities Act of 1933 and, accordingly, was not routine under § 240.17Ad-1(i) (5) or (8).

Implementation notes

This should not be treated as abstract recordkeeping only. These are the intake, item-availability, inquiry, registrar, and non-routine classification proofs that show how the processing system actually behaved.

We should identify where each record is created, whether it is generated by protocol/system behavior or by human review, and how it is retained in an easily accessible place for the first six months.

Task list

• Map 17Ad-6(a)(1) to item intake and availability workflows.
• Map 17Ad-6(a)(3)(i) to outside registrar workflows, if applicable.
• Map 17Ad-6(a)(6) to written inquiry and response workflows.
• Map 17Ad-6(a)(11) to non-routine item classification support.
• Identify system-generated records v. policy/manual records.
• Confirm where the first-six-month easily accessible copy lives.