SEC Final Rule Electronic Record Keeping Requirements	Rule Reference
1	Provides an "audit trail"alternative to the historical WORM requirement, among other things, that the "audit trail will permit re-creation of the original record if it is modified or deleted".	?
2	Retains WORM as an option for firms to use either in whole or in part	?
3	Requires both WORM and Audit trail solutions to be in human readable and reasonably usable electronic format - the application of this requirement to certain records may present certain difficulties for firms (i.e.: firms that have taken snapshots of their systems if such snapshots are nt machine readable)	?
4	Provides optionality with respect to the requirement to have a separate backup copy of required records by providing as an alternative the requirement to have "other redundacy capabilities that are designed to ensure access to the records required to be maintained perserved pursuant to 240.17a-3 and 240.17a-4"	?
5	Provides optionality with respect to the undertakings that must be filed with a firm's designating examining authority - importantly, while this provides an option to designate an internal officer to provide the undertakings instead of a third party, the interanl officer option may be seen by some firms as compliacted and difficult to implement.	?
6	Provides the optionality with tespect to the undertakings that are required to be provided by third-part storage providers such as cloud storage providers that don't have access to or the ability to provide records to regulators.	?
7	Reiterates the SEC's position that contracts that include provisions permitting the service provider to withhold, delete, or discard a firm's records required to be preserved (i.e.: for non-payment) are in violation of the securities laws, as well as indicates that cloud service provider contracts may need to be amended to comply with the new undertaking requirements	?
8	SBSEs without a prudential regulator will, for the first time, be required to comply WORM requirement, the audit trail requirement, or selectively apply one of those requirements to required records.	?
9	The compliance period for Broker Dealers is six months from publication in the Federal Register and twelve months for impacted SBSEs	?