Quick Answer
The retention trigger differs by row: most transaction records run from creation, account records run from account closing or from an update, examination reports run from the date of the report, manuals run from when the firm stops using them, and a few categories run for the life of the enterprise with no fixed end date.
Memorizing the number alone is not enough. The exam pairs the retention period with what starts the clock, so treat each row as a two-part fact, not one.
How Long Must Each Record Type Be Kept?
| Record type | Retention period | Clock starts | Accessibility |
|---|---|---|---|
| Blotters, general ledgers, customer ledger accounts, the securities record, and the two office listings of who can explain the records and which principal owns compliance procedures | 6 years | Creation of the record | First 2 years easily accessible |
| Order memoranda, retained communications, and most other transaction records | 3 years | Creation of the record | First 2 years easily accessible |
| Account cards or records showing the terms and conditions of opening and maintaining a customer account | 6 years | Account closing | Not separately specified |
| Customer account information later superseded by an update | 6 years | The date the information was updated | Easily accessible for the whole period |
| The last version of customer account information, or the original if it was never updated | 6 years | Account closing | Easily accessible for the whole period |
| Partnership articles, articles of incorporation, minute books, stock certificate books, Form BD and Form BDW filings and amendments, and registration licenses | Life of the enterprise, and of any successor enterprise | Not applicable, kept as long as the firm or a successor exists | No accessibility requirement |
| Compliance, supervisory, and procedures manuals | 3 years | The firm stops using the manual | Easily accessible for the whole period |
| Regulatory examination reports and reports furnished under a regulatory order or settlement | 3 years | The date of the report | Easily accessible for the whole period |
| Any FINRA record with no other specified retention period | 6 years | Creation of the record | Not separately specified |
| Written customer complaint records | 4 years | The rule states the period and no start date | Not separately specified |
| Negotiable-instrument authorizations, but only where the authorization is a separate document from the check or draft. The checks and drafts themselves need not be kept | 3 years | The authorization expires | Not separately specified |
Exam Tip: Gotchas
- "First two years easily accessible" attaches only to the general six-year and three-year buckets in the first two rows. It is not a universal rule.
- The organizational records kept for the life of the enterprise, such as articles of incorporation and minute books, carry no accessibility requirement at all. Manuals and examination reports carry a stronger one: easily accessible for their whole retention period, not just the first two years.
What Must a Firm Have Before It Takes a Customer's Check?
- The negotiable-instrument rule is a conduct rule before it is a retention rule. No firm and no associated person may take from a customer, or submit for payment, a check, draft, or other negotiable paper drawn on that customer's checking, savings, share, or similar account without the customer's express written authorization.
- That authorization may be the customer's own signature on the negotiable instrument.
- The three-year clock in the table above attaches only to the authorization record, and only where the authorization is a document separate from the instrument.
Why Do Two Six-Year Account-Record Periods Start on Different Dates?
- Two different rules both land on six years for account records, but they start the clock differently.
- The account-cards row (terms and conditions of opening and maintaining the account) runs six years from the account's closing date.
- The customer-account-information row restarts the six-year clock every time the account information is updated.
- Both customer-account-information rows must stay easily accessible for the whole six years, not just the first two.
Think of it this way: an account card that never changes still expires six years after the account closes. A piece of account information that gets updated five times in ten years resets its own six-year clock at every update, independent of when the account eventually closes.
Exam Tip: Gotchas
- Do not treat these two six-year rules as the same trigger just because they reach the same number. One question about a closed account is testing the account-cards clock. One question about an updated address or income figure is testing the customer-account-information clock.
What Should You Check on Exam Day?
- Pair every retention number with its trigger. The table above gives more triggers than the common four, and one row has no start date at all.
- Confirm whether "easily accessible" applies to the whole period, the first two years only, or not at all, before scoring an accessibility answer.
- Distinguish the account-closing trigger from the update trigger on the two six-year account-record rows; they are not interchangeable.