Most other records must be retained for three years. They include:
• Communications with the public, including retail and institutional communications and correspondence.
• A memorandum of each brokerage order given or received for the purchase or sale of securities for customer and firm accounts. This memorandum must include the following:
» Terms and conditions of the order
» Account for which it was entered
» Time the order was received
» Time of entry
» Price at which executed
» Identity of each associated person, if any, responsible for the account
» Identity of any other person who entered or accepted the order on behalf of the customer
» Time of execution or cancellation
• A memorandum of each purchase and sale for the firm’s account. This must show the same information as already mentioned.
• Copies of customer confirmations and copies of notices of all other debits and credits for customer accounts.
• Authorization records to draw funds from a customer’s accounts using a check or another negotiable instrument if the authorization is separate from the check. These must be kept for three years from the check’s expiration.
• Copies of office inspections.
• Identification data on beneficial owners of all accounts. This must include the beneficial owner’s name and address.
• The application for employment and/or any questionnaire for employment for any associated person. This must be kept for up to three years after employment is terminated.
• Fingerprint records for everyone associated with the firm, including each of its partners, directors, officers, and employees. Like employment applications, these fingerprint records must be kept until three years after employment is terminated.
