Jin J. Lee wishes to thank James Santangelo and Rosalind Conway for their contributions to this article. James is a director and Rosalind is a manager in PricewaterhouseCoopers' Information and Document Retention Services Practice.
If you're responsible for data retention related issues and work within the financial services industry, you may even remember the date: March 10, 2004. That is the day that the SEC brought - what represented at the time - an extraordinary "documents case" against Banc of America Securities (BAS). During a Securities and Exchange Commission (SEC) investigation into whether the company had engaged in improper trading practices, BAS repeatedly failed to promptly furnish key records requested by the SEC, including electronic mail - particularly with respect to an e-mail exchange relating to matters BAS knew was under investigation, specific compliance reviews and compliance and supervision records concerning the personal trading activities of a former senior employee of the firm. When BAS ultimately did respond to the SEC's request, its responses were often incomplete, inaccurate or unreliable. The consequences to BAS? Censure and a civil penalty of $10 million.
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