Last month, the SEC issued a new interpretation of 17a-4, which has long confused CIOs over what constitutes a valid storage medium. While the document states that archival systems must "preserve the records exclusively in a non-rewriteable, non-erasable format," it doesn't specify whether that means storage media that is inherently non-erasable and non-rewriteable--e.g., write-once read-many (WORM) optical platters --or whether certain software/hard disk drive-based systems might also fit the bill?
An initial read suggests that the SEC has ruled that certain disk-based systems, provided they meet certain criteria, may be acceptable. According to ESG's Gerr, the SEC "appears to make concessions to solutions that combine hardware and software to address the 17a-3 and 17a-4 requirements in a unique way."
That's good news for EMC, whose Centera array seems tailor-made for companies looking for a convenient, relatively economical way to store regulated data. This April, EMC released Centera Compliance Edition, which enhanced retention protection, increased access security
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and added support for permanent data deletion, or shredding, once a retention period expires.
The SEC's interpretation should also clear the way for other disk-based archival systems, says ESG's Gerr. Recent entrants into the space include Network Appliance, which recently announced SnapLock, an "open access data retention solution targeted at regulated data industries" that runs on its filers and Austin, TX-based RenewData, which is developing archival software that runs on generic hardware.
This was first published in June 2003