FINRA-Compliant Email Archive Migration.

The situation.

The client is a multi-office Registered Investment Advisor with a long client tenure and a substantial book of business. During a routine SEC exam, the examiner asked for archived emails in a specific format and time range. The firm's incumbent archive vendor could produce copies of the emails, but couldn't demonstrate the immutability required by FINRA 4511 / SEC 17a-4 — in other words, there was no audit-defensible proof that the archived records hadn't been modified or deleted.

The firm had a remediation window measured in weeks. We took the engagement.

What we did.

Migration

• Source-system audit to inventory all mailboxes and message counts across the existing archive
• Verified chain of custody for every message exported from the legacy archive
• Migration completed without email service interruption — advisors continued normal operations throughout
• Reconciliation report showing 100% of legacy messages accounted for in the new archive

New Archive Configuration

• True immutable WORM (write-once-read-many) retention with three-year minimum (client elected seven)
• Audit-ready search interface in the format examiners expect
• Per-message audit trail of access (who searched, when, what they retrieved)
• Role-based access for compliance officers, with separation from operational IT roles
• Configured for the specific requirements of FINRA 4511, SEC 17a-4, and Reg S-P

Documentation

• Written chain-of-custody report covering the migration itself
• Operating procedures for archive search, legal hold, and producer-of-record sign-off
• Tabletop exercise with the firm's compliance team to confirm the new system would survive a re-exam