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News September 19, 2011 Issue

Data Delivery Requirements Offer Helpful Hints

It should be safe to assume that if youíre on the receiving end of a request for information, the SECís Division of Enforcement will forward you a copy of this document as a courtesy.

For all the other folks, who donít want to have to be subject to an Enforcement inquiry just so they can get a look at how the SEC prefers to receive its information, thereís good news.

The SEC recently posted its Data Delivery Standards for persons providing requested information to the Division of Enforcement. The requirements also serve as guidance for best practices when producing documents to the SEC in the examination context as well.

Instructions such as include a "list of each piece of media (hard drive, thumb drive, DVD or CD) included in the production by the unique number assigned to it, and readily apparent on the physical media," and directions to encrypt the media and sweep it for viruses are just good sense.

Microsoft programs such as Excel and Outlook are accepted formats, as well as Lotus Notes. Audio files must include the call information ("metadata"), a list of at least seven data points identifying the callers, their numbers, date, time, and file identifier for the call.

For those firms that have yet to undergo an examination, the requirements also serve as a heads up for data organization, and provide a hint of the rigors of responding to SEC requests.