SEC 17a-4
Broker-dealer record-keeping for AI agent actions, with tier-split retention
SEC Rule 17a-4 sets retention floors for broker-dealer records. 17a-4(a) requires preservation of certain records for at least 6 years. 17a-4(b) requires others for at least 3 years. FINRA Rule 4511 applies a parallel retention floor on its members. AI agent actions that touch trade decisions, customer communications, or order routing fall under one of these tiers.
Asqav can sign submitted agent-action records with ML-DSA-65 (FIPS 204). It chains receipts per agent, and routes the retention floor automatically based on the regime tag the deployer attaches to the organisation's compliance_regimes array (sec_17a4a or sec_17a4b).
The receipt format is profiled in the IETF Internet-Draft draft-marques-asqav-compliance-receipts, which binds the format to the SEC retention obligation.
Obligations
| Section | Requirement | Asqav binding |
|---|---|---|
| 17a-4(a) | Preserve specified records for not less than 6 years. | Retention floor 2192 days enforced when compliance_regimes contains sec_17a4a. Tier-config refuses early deletion. Audit Pack export packages the window with a signed manifest. |
| 17a-4(b) | Preserve specified records for not less than 3 years, the first 2 readily accessible. | Retention floor 1096 days enforced when compliance_regimes contains sec_17a4b. Records are queryable through the verify and audit-pack endpoints across the full window. |
| 17a-4(f) | Records may be preserved on electronic storage media that preserves them in non-rewriteable, non-erasable format. | Hash-chain plus RFC 3161 anchor produces a tamper-evident chain even when the underlying storage is rewriteable. Any modification breaks the chain on verify. |
FINRA Rule 4511 inherits the 17a-4 floors and applies them to FINRA members. The same regime tag covers both. See the docs for the full mapping and the IETF draft for the binding text.