📜 What policy items can ensure proper safeguarding of rescinded legacy certificates? #4
Description
Important
Particularly, I want to address this in a way which doesn't require extensive Section 17(f)(1) program integration.1
This finished up staff questions while also relating deeply to Id. n.1. As we design which ought to solve 3 here and API 3, I'd really like to streamline communications into a single on-chain stream.
After finishing up Response 7's address change items, we'll need a strong team policy on certificate deletion, which was particularly highlighted as inadequate given the "bad" "agreement instructions" with lawyer based on outsourced forwarding. The exact takeaways reflected that:
Sending certificate to a place that’s not the fingerprinted TA.
Agents commonly stamping it "cancelled", perforating, and shredding.
Cannot have them (someone not through TA FBI process) blindly open certificates.
Ad12 as relevant basis for ensuring a "safeguarding" of investor information.
The team's subfolder in compliance policy needs "to talk about sending certificates as proper safeguarding" in a new process which defines "procedures for how certificates are cancelled and destroyed." This destruction and cancellation doc will likely come up in the next exam. I think the existing microshredded should do the job, with trust.
Footnotes
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Specifically, see 17 CFR § 240.17f-1 and Form X-17F-1A. 😥 ↩