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 signs every AI agent action with ML-DSA-65 (FIPS 204), 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.