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Maintaining Compliance with the SEC Designated Third Party (D3P) Rule

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In 1997, the Securities and Exchange Commission (“SEC”) issued Rule 17A-4(f), which authorized broker-dealers to store their required books and records in electronic format. Broker-dealers who elected to store records electronically were required by the rule to retain a third party (“Designated Third Party”or “D3P”) who had the ability to independently download electronically-stored information to another acceptable medium for the SEC’s review, (the “D3P Requirement”).