SEC Rule 17a-4 — books and records (electronic storage posture)
This page is generated from the requirement table the AiSSAY engine ships for this framework. When the engine produces an evidence pack, each row below gets a status computed from the operator's own records at that moment. This page shows the table, not anyone's results.
Informational mapping prepared by the operator's own tooling. Not a legal opinion, not a certification, and not a substitute for advice of counsel. It organizes the operator's records against the cited requirements; whether those records satisfy the requirements is a determination for the operator, counsel, and the examiner.
The requirement table
5 rows: 5 mechanism
| Requirement | Mechanism, duty or gap | Type |
|---|---|---|
| Records preserved in a manner that prevents alteration (WORM / audit-trail alternative) | append-only hash chain; corrections append, never overwrite; verification against an externally anchored tip | mechanism |
| Retention for the required period, readily accessible | per-record retain-until dates; deletion before expiry refused unless explicitly overridden with a reason, which the tombstone records; deletion blocked outright by legal hold | mechanism |
| An accurate index of records | store listing with run ids, timestamps and status | mechanism |
| Audit system providing accountability for access | complete access log: every read, write, hold and delete, with actor and reason | mechanism |
| Ability to furnish records promptly | full export at any time; records readable by someone who was not there | mechanism |
How a status is earned
- Evidenced
- a deterministic check ran against your records and the counts support the row. A store holding no relevant records reads unevidenced — a true statement, not a passing one. Empty never counts as clean.
- Delegated
- the mechanism is enforced by a system you already trust — a store sealed by your own key manager delegates access control to it, and the pack says the enforcing log is your key manager's, not ours. The pack names the endpoint the key manager was reached at. An AWS endpoint other than AWS's own default for the region reads delegated to that endpoint, with a request that you confirm it is your key management service. One backend — AWS KMS — has run against the real AWS KMS service; no other backend has.
- Test seam
- sealed by an in-process test backend — a stub, or a stand-in for the AWS client — and the status names which. No key manager enforces access. The seam is built and tested, and the pack refuses to call that delegation.
- Partially evidenced
- the mechanism is built and some of your runs carry its evidence, but not all — usually because they were sealed before the mechanism existed. The pack says how many runs are in each group, and never counts the missing ones as passing.
- Organizational
- the requirement is a procedure only people can perform. The pack names it as yours instead of dressing a policy up as a mechanism.
- Named gap
- the pack cannot evidence it — either the mechanism is not built, or no software can supply it — and it says which. The gap is printed, because a reviewer should read it here rather than discover it.
No status is typed in by hand: every status is recomputed from the store each time a pack is produced, the requirement and mechanism text is written and reviewed as part of the engine, and the dependency evidence comes from our release scan. A failing mechanism can never be read as evidence that the control works.