Reliable Designated Third Party (D3P) Services for Broker-Dealers
Request D3P ServicesSince 2007, Securities Industry Records Services, LLC (SIRS) has been a trusted provider of Designated Third Party (D3P) services, assisting FINRA-registered securities broker-dealers (B/Ds) in meeting their electronic recordkeeping obligations under SEA Rule 17a-4(f).
SEA Rule 17a-4(f)(4) mandates that broker-dealers who store required records electronically must do so in a non-rewriteable, non-erasable (WORM) format. A key component of this rule is the requirement for broker-dealers to engage a Designated Third Party (D3P) who has access to these records and can provide them to regulators if the broker-dealer is unable to do so.
17a-4(f)(3)(v) requires a B/D to engage the services of “a designated third party” who has access to and the ability to download records from the B/D's electronic recordkeeping system. To address this requirement, SIRS offers its D3P services. Through a contractual agreement, SIRS establishes access to the B/D's electronic recordkeeping system. For an annually renewable service charge of $500, SIRS will provide its services, including the signed undertaking letter required by 17a-4(f)(3)(v).
Under SEA Rule 17a-4(f), broker-dealers storing required records electronically must file a signed undertaking from an independent third party (D3P) or designated executive officer. The D3P agrees to access and download electronic records for regulators if the broker-dealer fails or is unable to provide them upon request.
Yes. SIRS routinely structures D3P Statements of Work to cover parent financial groups along with all operating broker-dealer affiliates under a single, unified annual retainer agreement.
Upon receiving a legitimate record request from a regulator (SEC, FINRA, or state authority), SIRS will notify your firm within three (3) business days. SIRS will then work collaboratively with your technical team to access designated electronic storage media and securely fulfill the request.
Once a Statement of Work and fee agreement are finalized, SIRS can execute and deliver the official SEA Rule 17a-4(f) undertaking letter within 24 to 48 hours for filing with your Designated Examining Authority (DEA).