Other Recordkeeping Requirements

The Series 24 candidate must remember each record type's retention period and what triggers the clock. The rule numbers themselves are not testable.

General Recordkeeping Requirements

The umbrella books-and-records requirement is covered in detail earlier in this unit. Briefly:

• Members must make and preserve all books and records required by the Securities Exchange Act, the SEC's books-and-records rules, and FINRA rules
• All FINRA-records preservation must comply with the SEC's records-retention rule format and accessibility standards
• The default retention for FINRA records with no specific period stated is 6 years: 6 years after account closure for account-related records, 6 years after the record is made for other records

The 6-year default is the fallback; the customer-account, complaint, and negotiable-instrument requirements below set their own retention periods that override the default.

Customer Account Information

Firms must maintain customer account information including an enumerated list of items. The records must be preserved according to the retention triggers below.

Required Customer Account Information

The enumerated list includes:

• Name and residence
• Whether of legal age
• Tax identification or Social Security number
• Occupation, employment status, and employer
• For each associated person whose name appears on the account: their name and CRD number
• Signed by the associated person responsible for the account
• Approved or accepted by a principal
• For discretionary accounts: the dated, manual signature of each named natural person authorized to exercise discretion, plus the date discretion was granted
• For accounts of individual customers: the customer's date of birth, employment status, annual income, net worth, and investment objectives

The firm must update the information at least every 36 months (every 3 years) for accounts where the firm has provided investment advice within that period.

Retention Periods

The retention is keyed both to updates and to account closure. A firm that updates account information every 3 years generates a series of 6-year retention obligations on each updated version, plus a 6-year-after-closure obligation on the final version.

Exam Tip: Gotchas

• Customer-account-information retention is 6 years AFTER UPDATE and 6 years AFTER CLOSURE. Each updated version triggers its own 6-year clock, and the final version's clock starts only when the account is closed. A firm that purges updated versions at 6 years from the open date (not from the update date) is non-compliant.
• Discretionary accounts require a dated, MANUAL signature, not just an electronic checkbox. Discretionary authority is one of the few places where electronic signatures are not sufficient on their own under standard exam fact patterns. Treat "manual" as the safe answer for discretionary authority.

Written Customer Complaint Records

Each Office of Supervisory Jurisdiction (OSJ) must keep a separate file of written customer complaints (or a separate record with cross-reference). This requirement is covered in detail in Unit 7: Disciplinary Actions and Customer Disputes, in the customer-complaint-recordkeeping section.

For memorization purposes, the retention is:

The 4-year complaint retention is longer than the SEC's 3-year complaint floor but shorter than the 6-year default. The 4-year period is one of the testable items in the retention pattern.

Pre-Authorized Negotiable Instrument Records

For pre-authorized negotiable instruments (e.g., checks, drafts) drawn on a customer's account, where the customer authorization is separate from the instrument itself:

The clock runs from expiration, not from the date the authorization was granted. A 5-year authorization triggers an 8-year preservation cycle (5 years of active use plus 3 years after expiration).

Exam Tip: Gotchas

• The negotiable-instrument-authorization clock starts when the authorization EXPIRES, not when it is granted. A 10-year authorization granted in 2020 generates a preservation obligation through 2033 (10 + 3). The exam may probe when the clock starts; it is at expiration.

Changes in Account Name or Designation

Before a customer order is executed, the account name or designation must be placed on the order ticket. Any subsequent change in account name or designation requires:

• The written approval of a qualified registered principal
• Approval based on essential facts justifying the change
• The principal must record the essential facts and the approval

What This Catches

The account-name-change requirement prevents two failure modes:

• A registered representative unilaterally changing an account name on a ticket (e.g., to move an order from one customer to another after the fact)
• A clerical correction made without principal review (the "fat-finger" excuse)

A change in account name or designation is treated as a substantive event that requires principal review with documented justification, not a clerical fix.

Exam Tip: Gotchas

• A registered representative or clerk who unilaterally changes an account name on a ticket commits a books-and-records violation PLUS a potential supervisory failure. The exam may present a fact pattern where a rep "fixes" an account name without principal sign-off; this is a books-and-records violation and exposes the supervisor.
• The principal must record ESSENTIAL FACTS, not just sign off. A principal who approves the change without documenting the underlying justification has not satisfied the requirement. Approval alone is insufficient; the supporting facts must be captured.

Other Records-Series Requirements (Brief)

The per-event and quarterly reporting framework is its own substantial topic and is treated in Unit 7 alongside the customer-complaint and disciplinary-action material it interacts with.

The 6-4-3 Retention Pattern

The single most testable feature of the records-series rules for the Series 24 is the retention pattern across the three flagship records:

Memory Aid: "6-4-3 ledger play": Picture a baseball 6-4-3 double play filed in your records ledger. Customer info goes to shortstop (6 years), complaints flip to second base (4 years), and authorizations throw to first (3 years). The double-play sequence is the retention ladder: 6 - 4 - 3.

Exam Tip: Gotchas

• The 6-4-3 pattern is a frequent exam target. Memorize that customer info = 6, complaints = 4, negotiable-instrument authorizations = 3. The default 6-year retention is the fallback only when no specific record-type rule applies.
• Don't confuse customer-account 6-year-after-update with the default 6-year-after-record-made. They are both 6 years, but the trigger is different. Customer-account retention keys off updates and account closure; the default keys off the record being made (for non-account records) or account closure (for account-related records).