compliance

2 pathways. One architecture. The regulator's question takes one query, not 3 weeks.

For 2 decades the only acceptable answer to FINRA 17a-4 and SEC 17a-4 was WORM storage — write-once, read-many physical or virtual media. The 2022 audit-trail amendment changed that. Cryptographic equivalence is now an explicit alternative pathway, and the regulator's tooling will verify it directly.

That matters because most broker-dealers were architecting around WORM constraints — separate archive systems, separate retention engines, separate audit trails — that don't compose with modern AI, modern eDiscovery, or modern records-of-record discipline. The cryptographic-equivalence pathway is the architectural exit from that legacy.

TeamSync runs both pathways. Same platform, same audit chain, same regulator-acceptable evidence pack — your choice on which is the right model for your specific examination history and your firm's risk posture.

Talk to the FSI compliance team · Read the FSI vertical hub · Read the tamper-evident audit pillar


What 17a-4 actually requires.

The rule covers broker-dealer books and records. The requirements that drive most architectural decisions:

Requirement What it actually says
Retention period 6 years for most records; lifetime-of-firm-plus-three-years for some categories
Immutability Records cannot be altered or deleted during the retention period
Accessibility Must be promptly producible to the regulator (FINRA / SEC examination, subpoena)
Indexing Records must be indexed for efficient retrieval
Off-site storage Duplicate copy at a separate location
Audit trail Complete log of all access and any (legitimate) modifications
Designated third party (D3P) A third party with the ability to provide the records to the regulator if the firm fails to

The 2022 amendment introduces the cryptographic-equivalence alternative for the immutability requirement.


Pathway 1 — WORM storage.

The classical pathway. Records written to immutable media; the immutability is a property of the storage layer.

Element TeamSync's WORM-pathway implementation
Storage layer Immutable object storage with write-once enforcement; supports physical WORM, S3 Object Lock in Compliance mode, and equivalent
Retention enforcement Per-document-type retention rules, applied at the storage layer
Audit trail Native, on the platform; same chain as the cryptographic-pathway records
D3P Configurable; we work with the major D3P providers your firm uses
Examination evidence Generated artifact; regulator-acceptable format

For firms with established WORM infrastructure that's working, this pathway is incremental.


Pathway 2 — Cryptographic equivalence (the 2022 amendment).

The new pathway. Records stored in modern, mutable media; the immutability is a property of the cryptographic audit chain.

Element TeamSync's cryptographic-pathway implementation
Storage layer Modern object storage with replication and durability; mutable at the storage layer
Immutability mechanism Merkle hash chain anchored to external timestamp authority; modification is mathematically detectable
Retention enforcement Same platform-level rules; not dependent on storage immutability
Audit trail Native; the cryptographic chain is the trail
D3P Cryptographic chain anchors are themselves third-party verifiable; D3P arrangements supported additionally
Examination evidence Generated artifact with cryptographic proof of immutability

For firms exiting WORM infrastructure or designing greenfield deployments, this is the modern pathway.


What composes onto the platform.

Most 17a-4 implementations are recordkeeping-only. The architectural advantage of TeamSync is that the recordkeeping platform composes with the rest of the platform — AI copilot, eDiscovery, surveillance evidence — without leaving the regulator-acceptance perimeter.

Capability What it does inside the 17a-4 perimeter
Intelligent Repository The records platform; covers both pathways
DocuTalk AI grounded in the recordkeeping corpus; permissions-aware; audit-anchored
Semantic Search Federated search across the recordkeeping estate
eDiscovery Hold and collection at the recordkeeping source
Agentic AI Workflow Surveillance agents whose actions are anchored
Audit ledger The chain every event writes to

The composition is what makes the 17a-4 program future-proof against the next examination cycle's expectations.


What the FINRA / SEC examination actually looks like.

The examination pattern that's emerging post-2022:

Examination request What you produce
"Show us the complete recordkeeping for accounts X, Y, Z over period A–B" Generated package with cryptographic chain of custody
"Show us the audit trail for any access to those records" Same chain; access events are queryable
"Show us how you'd respond to a tamper claim" Cryptographic proof from the chain anchor
"Show us the records of any AI interactions involving those accounts" AI audit-chain segment for the same accounts
"Show us the surveillance evidence for any flagged communications" Surveillance audit pack with explainability

Each of these used to be a multi-day reconstruction. Each is now a query.


What changes for the compliance and surveillance teams.

Activity Before With TeamSync
Recordkeeping evidence assembly Multi-week project Generated artifact
Surveillance audit defensibility Procedural narrative Cryptographic chain
AI-on-recordkeeping CISO sign-off Multi-quarter process Architectural answer
Cross-system reconciliation for examination Reconciliation spreadsheet One query
2022 amendment migration path Engineering project Configuration choice

How customers compare TeamSync for 17a-4.

The 17a-4 evaluation usually compares against:

  • OpenText InfoArchive — strong on archival immutability; the modern AI copilot and the per-cluster pricing model are weaker
  • Smarsh / Global Relay — strong on communications archiving; the broader books-and-records story is narrower
  • Microsoft Purview / Compliance Manager — strong inside M365; the cross-source 17a-4 perimeter is weaker
  • In-house WORM + GRC stitching — most flexible; the cryptographic-pathway story is on you to build

For specific comparisons: - TeamSync vs OpenText - TeamSync vs SharePoint + M365


Read further.

Talk to the FSI compliance team

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