SEC COMPLIANCE ARCHIVE QUICK GUIDE (FOR IMAGESILO SUBSCRIBERS)

Transcription

1 SEC COMPLIANCE ARCHIVE QUICK GUIDE (FOR IMAGESILO SUBSCRIBERS) MuniMetriX Systems Corporation 1575 Delucchi Lane, Suite 223 Reno, NV Support: (800) Sales: (800) Version3-NYL-M

2 TABLE OF CONTENTS INTRODUCTION... 3 SETTING UP A DATA TRANSFER DOWNLOAD JOB... 4 For New Customers... 4 Things to Do Prior to Download... 4 Things to Do After Your Download... 4 BURNING YOUR DATA TO DISCS... 5 Media Requirements... 5 CD/DVD Media... 5 CD/DVD Burning Software... 5 Setting Up the Burn Job... 6 Verify Data on CD CD LABELING SUBMISSION PROCEDURES Sign an Agent Certification Form Document Destruction CHECK LIST Appendix A Submission Form Appendix B Agent Certification Form... 16

3 INTRODUCTION New York Life requires that specific procedures be followed in order to safely and correctly maintain a paperless office in compliance with SEC Rule 17a-4(f). New York Life agents who have subscribed to the ImageSilo web-based document repository are considered to be in compliance and may destroy their documents once the procedures outlined below have been followed, unless otherwise instructed by New York Life. This SEC Archive Guide is just a quick reference meant to guide you through the basic steps of performing the quarterly archive of your ImageSilo data. Listed below are the steps involved in performing your SEC Quarterly Archive. Each step is explained in more detail on the following pages of this guide. 1. For new customers who are just beginning this process, MuniMetriX will assist you in setting up an automated data transfer job on a designated PC in your office for the purpose of downloading your backup files. 2. On or around the first day of the month after your quarter ending date, MuniMetriX will run a backup of your ImageSilo data. 3. Every quarter on the date specified in your Data Transfer Manager Download your encrypted and packaged backup job will automatically be downloaded to your designated PC. 4. Once downloaded, you will then burn CDs/DVDs of your data one of which will be mailed to MuniMetriX as the third party for the SEC/NASD. 5. Once you receive a confirmation receipt showing that your media has been received and logged, you may then destroy any files/documents that were included in that quarterly backup, unless otherwise instruction by New York Life. 3

4 SETTING UP A DATA TRANSFER DOWNLOAD JOB For New Customers For new customers, you will be contacted via by MuniMetriX a few weeks prior to the end of the quarter informing you that it is time to do your SEC Quarterly Backup. You will need to contact our office sometime prior to your scheduled backup to schedule a time for MuniMetriX to assist you with the configuration of a Data Transfer Download job on your PC. The purpose of the Data Transfer Download job is to securely transmit your ImageSilo backup files to a designated PC in your office for the purpose of burning the data to CD or DVD media. Once your download job has been configured, it should then run automatically every quarter. When configuring your download job, MuniMetriX will create a folder on your local hard drive (generally C:\ImageSilo\SEC Download). This will be the destination folder for your download files. Things to Do Prior to Download On the night your download job is scheduled to run, you should do the following: The PC designated to download your backup should be left ON. Make sure that your PC is not set to go into hibernate or standby mode prior to the download. Your Power Options can be found in your Control Panel. Make sure no Windows Updates are schedule to run on the night of your download. Make sure that your SEC Download folder is empty. Things to Do After Your Download The next working day after your download is scheduled to run, you should do the following: Look in your SEC Download folder to make sure that your download was successful. There should be new files in your SEC Download folder. Note: You should have received an e- mail from MuniMetriX telling you exactly how many files you should have in your SEC DOWNLOAD folder. If you do not see the number of files that MuniMetriX provided you, it is possible that your files are still downloading. It can take several hours depending on how many files are downloading and your internal Download speed. If your SEC Download is empty, call MuniMetriX so we can determine why the download job did not run, and set up your job to run again. There are several factors that can cause a job to fail, such as failure to leave the PC on, Internet connectivity issues, etc. 4

5 BURNING YOUR DATA TO DISCS You are now ready to burn your downloaded data files (located in your C:\ImageSilo\SEC Download folder) to CD or DVD media. You must have a CD or DVD burner drive as well as CD/DVD burning software. If you have any questions about burner drives and software, feel free to contact MuniMetriX for assistance. Media Requirements CD/DVD Media Only compliant media should be used for your SEC Compliant Archive. Compliant media consists of DVD-ROM (DVD-R or DVD+R media) or CD-ROM (CD-R or CD+R media) which are by design, non-rewritable and non-erasable. Do not use re-writable media such as CD-RW or DVD-RW. MuniMetriX strongly recommends using DVD-R or DVD+R due to the fact that one DVD+R can hold almost seven times more data than a CD+R. CD/DVD Burning Software Use a CD/DVD writing application that automatically verifies the accuracy of the recording process. Some purchased CD/DVD drives come with lite versions of CD/DVD writing software that may or may not meet these requirements. Applications such as Nero by Ahead Software or CD Creator by Roxio are recommended applications. SEC 17a-4 requires that you serialize the CD/DVDs that are created. Most CD/DVD writing applications automatically encode the CD/DVD with a date and time code that is unique and satisfies the serialization requirement. Also the CD/DVDs themselves should be serialized, dated, and clearly labeled as instructed later in this guide. 5

6 Setting Up the Burn Job The process of setting up your burn job will differ depending on what burning software you are using. The basic steps for burning your data to disc are as follows: 1. When adding files to your burn project, you will choose the SEC DOWNLOAD folder which contains all of your packaged, encrypted backup files. 2. When naming your disc or the volume label of your disc, use the name: NYL_SEC. 3. You will need to burn three sets of discs. 4. Make sure that during the burning process that the disc is finalized (meaning that you cannot write additional files to the disc). This may also be indicated by an option for creating a multisession disc. Make sure that the option for creating a multisession disc is NOT selected. 5. Make sure that the job is set to automatically verify the accuracy of the recording process. Below are illustrations of the process using the Nero Express burning software. Choose your CD/DVD recorder. Choose Data disc. 6

7 Choose Add to add data to your disc. 7

8 Browse to your SEC DOWNLOAD FOLDER. The contents of the SEC Download folder should be displayed as shown below. Select all of the files displayed and click the click the Add button. Click the Finish button. 8

9 Click the Next button. 9

10 The disk name should be: NYL_SEC Choose 3 copies. Allow files to be added later (multisession disc) should be UNCHECKED. Verify Data on disc after burning should be CHECKED. Click the Burn button to start burning your disc. 10

11 Verify Data on CD Once you have burned your three sets of discs, we recommend that you take a few extra minutes to check the discs in a drive from another PC just to make sure that you can see the files on the disc. Simply insert the disc into a CD or DVD-ROM drive. Using Windows Explorer or My Computer, browse to your CD or DVD-ROM drive and make sure you can see the files listed on the disc. You do not need to try to open the files on the disc as these files are zipped and encrypted. Just verify that the files are on the disc. 11

12 CD LABELING We recommend that you label your discs using either a commercial label writing software or you may print neatly on your disk using a fine-point Sharpie. Do not use a regular pen, marker or pencil that can damage the disc or can easily be wiped off or smudged. The following information should be included on the labels of your archive discs. NYL-SEC 17a-4(f) Compliance Archive Submission Date Quarter Ending Date CP Acct# (provided to you by MuniMetriX) Agency Name Agent Name Disc # (Ex: Disk 1 of 1; 2 of 3) 12

13 SUBMISSION PROCEDURES The three sets of compliant media should be submitted as follows: 1. The first set is to be submitted to MuniMetriX Media Storage c/o Iron Mountain, 165 Catron Drive, Reno, Nevada as outlined on the Submission Form (See Appendix A) provided to you from MuniMetriX. NOTE: When shipping your media to Iron Mountain, we recommend that you secure the disc(s) in a jewel case or disc jacket of some kind in order to protect it from being damaged during transit. 2. The second set is your official record which as required both by regulation and New York Life rules you must retain onsite in your office. 3. The third set is for disaster recovery which must be maintained in a secure location offsite so as to comply with regulatory requirements. Sets two and three must be retained for 5 years from the creation date. Sign an Agent Certification Form Sign an Agent Certification Form (See Appendix B) attesting to the completeness of the image storing process and send (via mail or ) a copy of the certification to your Managing Partner for inclusion in the supervisory file and a copy to MuniMetriX. (Our mailing address can be found on the cover of this guide). Keep the original in your Imaging Administration File. This form should have already been supplied to you by your home office. Document Destruction Unless you have been informed otherwise by New York Life, you CANNOT dispose of your paper until after you have received a confirmation receipt from the MuniMetriX/Iron Mountain storage facility. They will send you a confirmation receipt when they have received your media and logged it into their system. Once you have received it, keep the original notification from Iron Mountain with your Imaging Administration File and send a copy to your Managing Partner and MuniMetriX. Then follow the procedures outlined in the 10/25/04 Field News titled Secure Document Destruction by Michael Gordon. 13

14 CHECK LIST Use the following check list to verify that you have completed all of the required steps for your quarterly SEC Compliance Archive. Prior to your scheduled download, verify that the destination folder (SEC DOWNLOAD) for your downloaded files is empty. (IMPORTANT!) Make sure your PC is left on the night of the download. Look at the power settings on your PC to make sure that your PC will not go into Standby or Hibernation mode. Make sure no Windows Updates are scheduled to run. All of these things can interfere with or prevent your download. The day after your download is scheduled to run, check your SEC DOWNLOAD folder to see if the download ran successfully. If not, call MuniMetriX immediately. Burn 3 sets of data discs. Verify contents of discs, finalize, and properly label discs. Submit one set of media to the MuniMetriX/Iron Mountain Storage Facility as outlined in your Submission Form Once you have received a Confirmation Receipt that your disc was received and logged, complete an Agent Certification Form and send, along with a copy of your Iron Mountain confirmation receipt, to both your Managing Partner and MuniMetriX 14

15 Appendix A Submission Form 15

16 Appendix B Agent Certification Form 16