Books and records retention calculator
Pick the firm type and the record, enter the date the rule counts from, and get the keep-until date, the earliest day the record may go, and the first-years window the rule names. The SEC record retention requirements for advisers and the FINRA record retention requirements for broker-dealers set different periods and start them on different days; the tool keeps them apart and says plainly where a rule is silent.
Retention calculator: the tool
Retention calculatoradviserdeck.com
Pre-filled with an example: an adviser’s client email last written on March 14, 2026, with a December 31 fiscal year end.
Letters and emails on recommendations, funds or securities received or delivered, orders, and performance (204-2(a)(7)).
The tool uses the last day of the month you pick.
Keep until at least
December 31, 2031
17 CFR 275.204-2(a)(7), (e)(1)
- The period startsDecember 31, 2026
- In an appropriate office of the investment adviser throughDecember 31, 2028
- Kept in an easily accessible place throughDecember 31, 2031
- Destroy not beforeJanuary 1, 2032
Year 0: December 31, 2026
- First 2 years: in an appropriate office of the investment adviser2 years
- The rest of the period, still in an easily accessible place3 years
17 CFR 275.204-2(a)(7), (e)(1)
Rule 204-2 and 17a-4 periodsCard 01
- Advisers, most records5 years17 CFR 275.204-2(e)(1)
- Of which in an appropriate office of the adviserfirst 217 CFR 275.204-2(e)(1)
- Advisers, advertisements and performance backup5 years17 CFR 275.204-2(e)(3)(i)
- Adviser charters and minute books, after the firm ends3 years17 CFR 275.204-2(e)(2)
- Broker-dealer blotters, ledgers, securities record6 years17 CFR 240.17a-4(a)
- Broker-dealer communications, confirmations, order tickets3 years17 CFR 240.17a-4(b)
- Of which in an easily accessible placefirst 217 CFR 240.17a-4(a), (b)
- Account terms records, after the account closes6 years17 CFR 240.17a-4(c)
- FINRA records with no stated period6 yearsFINRA Rule 4511(b)
What it computes
Three answers for one record: the date the retention period starts, the date it ends (the keep-until date, with the day after it as the earliest the record may go), and the end of the first-years window, when the rule names one. Pick the firm type first, because the two rulebooks never share a period. An adviser’s records follow Advisers Act Rule 204-2; a broker-dealer’s follow Exchange Act Rule 17a-4, which FINRA Rule 4511 requires members to meet.
- Advisers count from the end of the fiscal year in which the last entry was made17 CFR 275.204-2(e)(1)
- Broker-dealer blotters, ledgers and communications: the rule gives a length but no start day17 CFR 240.17a-4(a), (b)
- Some records count from an event: an account closing, a report date, a manual retired17 CFR 240.17a-4(c), (e)
The two windows are not the same thing. Rule 204-2 keeps most adviser records in an easily accessible place for the whole five years and the first two of them in an appropriate office of the adviser. Rule 17a-4(a) and (b) keep blotters, ledgers, confirmations and communications for six or three years, the first two in an easily accessible place; the event-based records in 17a-4(e) stay easily accessible throughout. Where the records live, and how they are stored, is a separate question: the 17a-4(f) storage conditions bind broker-dealers only, and the archiving requirements matcher sorts out which channels must be captured at all.
A firm registered as both an adviser and a broker-dealer works out each record under the rule that makes it required. Rule 204-2(h)(1) lets a record kept under 17a-3 and 17a-4 that is “substantially the same” as the adviser record count for 204-2. To list which records your firm must make in the first place, start with the books and records checklist generator.
Worked example
Take the tool’s own default. An adviser with a December 31 fiscal year end last wrote to a client about a recommendation on March 14, 2026. The email is a written communication under Rule 204-2(a)(7), so it follows 204-2(e)(1): five years “from the end of the fiscal year during which the last entry was made.” The fiscal year closes on December 31, 2026, so the record is kept until at least December 31, 2031, and in an appropriate office of the adviser through December 31, 2028. The same email sent from a broker-dealer would fall under 17a-4(b)(4) instead: three years, the first two easily accessible.
Seven records, counted by the rule text
| Record | Date entered | Period starts | First window ends | Keep until at least |
|---|---|---|---|---|
| Adviser: client email (204-2(a)(7)) | Mar 14, 2026 | Dec 31, 2026 | Dec 31, 2028 | Dec 31, 2031 |
| Adviser: ledger, June 30 year end (204-2(a)(2)) | Aug 10, 2026 | Jun 30, 2027 | Jun 30, 2029 | Jun 30, 2032 |
| Adviser: advertisement last disseminated (204-2(e)(3)(i)) | Oct 22, 2026 | Dec 31, 2026 | Dec 31, 2028 | Dec 31, 2031 |
| Broker-dealer: trade confirmation (17a-4(b)) | Mar 14, 2026 | Mar 14, 2026 | Mar 14, 2028 | Mar 14, 2029 |
| Broker-dealer: blotter entry (17a-4(a)) | Mar 14, 2026 | Mar 14, 2026 | Mar 14, 2028 | Mar 14, 2032 |
| Broker-dealer: account closed (17a-4(c)) | May 1, 2026 | May 1, 2026 | None named | May 1, 2032 |
| Broker-dealer: unusual-activity report (17a-4(e)(8)) | Jan 15, 2026 | Jan 15, 2026 | None named | Jul 15, 2027 |
17 CFR 275.204-2(e)(1), (e)(3)(i); 17 CFR 240.17a-4(a), (b), (c), (e)(8)
Two things in the table are worth a second look. The June 30 adviser counts from June 30, 2027, because an August 2026 entry falls in the fiscal year that ends then; a later fiscal year end pushes every date out. And the advertisement counts from the year it was last disseminated, not from the year it was first used, so an ad that stays in use keeps pushing its own start date out.
The rule text
The calculator turns on three sentences, one from each rulebook. Every period in the tool is one of these, or a paragraph that sets its own.
Note what the second sentence leaves out. Rule 204-2 names the day an adviser’s five years start; Rule 17a-4(a) and (b) name the length and the first-two-years window but no start day. Rule 4511(c) adds that FINRA records are kept “in a format and media that complies with SEA Rule 17a-4.” Before you act on a date, check it with your compliance counsel; the tool is a reading of the rule text, not legal advice.
Where the rule says so
Every record type in the tool, with the rule’s own words and the paragraph to cite. Open a row to read it. The full text is on the eCFR for Rule 204-2 and Rule 17a-4, and in FINRA’s rulebook for Rule 4511.
Investment advisers: Rule 204-2
Written communications about advice, funds and orders
Letters and emails on recommendations, funds or securities received or delivered, orders, and performance (204-2(a)(7)).
“shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.”
5 years, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(7), (e)(1)
Journals, ledgers, order memoranda and financial records
Journals, ledgers, order memoranda, check books and bank statements, bills, trial balances and financial statements (204-2(a)(1)-(6)).
“shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.”
5 years, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(1)-(6), (e)(1)
Written agreements with clients
Every written agreement with a client or relating to the advisory business (204-2(a)(10)).
“shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.”
5 years, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(10), (e)(1)
Brochures, supplements and Form CRS
Each brochure, brochure supplement and Form CRS, every amendment, and the record of delivery dates (204-2(a)(14)).
“shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.”
5 years, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(14), (e)(1)
Access-person reports and code violations
Each access-person report and the record of code-of-ethics violations and actions taken (204-2(a)(12)(ii), (a)(13)(i)).
“shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.”
5 years, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(12)(ii), (a)(13)(i), (e)(1)
Records of the annual compliance review
Records documenting the annual review of the compliance policies and procedures (204-2(a)(17)(ii)).
“shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.”
5 years, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(17)(ii), (e)(1)
Advertisements and performance backup
Each advertisement disseminated and the working papers behind any performance shown (204-2(a)(11), (a)(16)).
“not less than five years, the first two years in an appropriate office of the investment adviser, from the end of the fiscal year during which the investment adviser last published or otherwise disseminated”
5 years, counted from the end of the fiscal year during which the adviser last published or otherwise disseminated it; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(e)(3)(i)
Approvals of access persons' securities purchases
Each decision, with its reasons, approving an access person's acquisition of securities under Rule 204A-1(c).
“for at least five years after the end of the fiscal year in which the approval is granted.”
5 years, counted from the end of the fiscal year in which the approval was granted.
17 CFR 275.204-2(a)(13)(iii)
Code of ethics and compliance policies (each version)
Each version of the code of ethics and of the written compliance policies and procedures (204-2(a)(12)(i), (a)(17)(i)).
“that are in effect, or at any time within the past five years were in effect;”
5 years, counted from the day the version stopped being in effect (by our reading of the rule).
17 CFR 275.204-2(a)(12)(i), (a)(17)(i)
Code acknowledgments and access-person lists
Each supervised person's written acknowledgment of the code, and the list of access persons (204-2(a)(12)(iii), (a)(13)(ii)).
“for each person who is currently, or within the past five years was, a supervised person of the investment adviser.”
5 years, counted from the day the person stopped being a supervised or access person (by our reading of the rule).
17 CFR 275.204-2(a)(12)(iii), (a)(13)(ii)
Partnership articles, charters and minute books
Partnership articles and amendments, articles of incorporation, charters, minute books and stock certificate books.
“shall be maintained in the principal office of the investment adviser and preserved until at least three years after termination of the enterprise.”
3 years, counted from the termination of the enterprise; kept in the principal office of the investment adviser.
17 CFR 275.204-2(e)(2)
Broker-dealers: Rule 17a-4 and FINRA rules
Communications sent and received (email, texts, chat)
Originals of all communications received and copies of all sent, with any approvals, including inter-office memoranda (17a-4(b)(4)); FINRA Rule 3110.09 points associated persons' correspondence to the same period.
“for a period of not less than three years, the first two years in an easily accessible place”
3 years, counted from the date you entered (the rule does not say when the period starts); the first 2 years in an easily accessible place.
17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09
Blotters, ledgers and the securities record
Blotters, general ledgers, customer account ledgers, the securities record and the 17a-3(a)(21)-(22) lists (17a-4(a)).
“for a period of not less than 6 years, the first two years in an easily accessible place”
6 years, counted from the date you entered (the rule does not say when the period starts); the first 2 years in an easily accessible place.
17 CFR 240.17a-4(a)
Order tickets, confirmations, complaint and approval records
Order and trade memoranda, confirmations, complaint, compensation and communications-approval records, bank statements, bills, trial balances and written agreements (17a-4(b)).
“for a period of not less than three years, the first two years in an easily accessible place”
3 years, counted from the date you entered (the rule does not say when the period starts); the first 2 years in an easily accessible place.
17 CFR 240.17a-4(b), (b)(1)
Account opening and terms records
Account cards or records on the terms and conditions of opening and maintaining a customer's account (17a-4(c)).
“for a period of not less than six years after the closing of any customer's account”
6 years, counted from the closing of the customer's account.
17 CFR 240.17a-4(c)
Customer account information and Reg BI records
Natural-person account record information (17a-3(a)(17)) and Reg BI records (17a-3(a)(35)).
“until at least six years after the earlier of the date the account was closed or the date on which the information was collected, provided, replaced, or updated”
6 years, counted from the earlier of the date the account closed or the date the information was collected, provided, replaced or updated; kept in an easily accessible place.
17 CFR 240.17a-4(e)(5); FINRA Rule 4512.01
Associated-person questionnaires and applications
The questionnaire or application for employment of each associated person (17a-3(a)(12)).
“until at least three years after the associated person's employment and any other connection with the member, broker or dealer has terminated”
3 years, counted from the end of the associated person's employment and any other connection with the firm; kept in an easily accessible place.
17 CFR 240.17a-4(e)(1)
Compliance, supervisory and procedures manuals
Each compliance, supervisory and procedures manual, with every update, modification and revision (17a-4(e)(7)).
“until three years after the termination of the use of the manual”
3 years, counted from the termination of the use of the manual; kept in an easily accessible place.
17 CFR 240.17a-4(e)(7)
Examination reports and regulator-requested reports
Each report a regulator requested under an order or settlement, and each examination report (17a-4(e)(6)).
“until three years after the date of the report”
3 years, counted from the date of the report; kept in an easily accessible place.
17 CFR 240.17a-4(e)(6)
Reports reviewing unusual account activity
Reports produced to review for unusual activity in customer accounts (17a-4(e)(8)).
“until eighteen months after the date the report was generated”
18 months, counted from the date the report was generated; kept in an easily accessible place.
17 CFR 240.17a-4(e)(8)
Form CRS and its delivery records
Each Form CRS and the record of the date it was given to each retail investor (17a-3(a)(24)).
“as well as a copy of each Form CRS, until at least six years after such record or Form CRS is created”
6 years, counted from the date the record or Form CRS was created; kept in an easily accessible place.
17 CFR 240.17a-4(e)(10)
Reg S-P incident and notification records
Documentation of detected unauthorized access to customer information, the response, and the notification determination (17a-4(e)(14)(ii)-(iii)).
“for three years from the date when the records were made”
3 years, counted from the date the record was made; kept in an easily accessible place.
17 CFR 240.17a-4(e)(14)
Supervisory designations record
The record of the firm's supervisory designations under FINRA Rule 3110(b)(6).
“for a period of not less than three years, the first two years in an easily accessible place”
3 years, counted from the date you entered (the rule does not say when the period starts); the first 2 years in an easily accessible place.
FINRA Rule 3110(b)(6)
FINRA records with no stated period
Any FINRA book or record for which no FINRA or Exchange Act rule sets a period (FINRA Rule 4511(b)).
“Members shall preserve for a period of at least six years those FINRA books and records for which there is no specified period under the FINRA rules or applicable Exchange Act rules.”
6 years, counted from the date you entered (the rule does not say when the period starts).
FINRA Rule 4511(b)
Charters, minute books, Forms BD and licenses
Partnership articles or charters, minute books, stock certificate books, all Forms BD and BDW with amendments, and registration licenses (17a-4(d)).
“during the life of the enterprise and of any successor enterprise”
No end date while the firm or a successor exists.
17 CFR 240.17a-4(d)
The communications rows are where text and chat messages come in. The guide to off-channel communications covers which messages count, and the comparisons of email archiving software and SEC 17a-4 compliant storage read each vendor against these periods.