Fine for a firm that can delete. A firm inside a retention window cannot, so the cap is not a ceiling it can manage — it is a date it will arrive at.
Financial services
A financial services phone system: retention is not one number
It depends on which record and which registration — and the number most vendor pages print is the wrong one for a phone call. Here is which window applies, what it does to your plan choice, and the part where we tell you to go buy something else as well.
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- The window depends on the record
- You may not delete inside it
- You will still need an archiver
Start with the right rule
“Six years for everything” is the misreading this page exists to correct
It is repeated on almost every page in this category, and it is a reasonable mistake: the six-year number is real, it is just attached to something else. Getting it right matters in both directions — under-retaining is a finding, and over-retaining on the assumption that six years is the floor means storing records you were never obliged to keep, which is its own kind of exposure.
Communications have a specified period, so the catch-all never reaches them. The rule that sets it is SEA Rule 17a-4(b)(4), and call recordings, voicemail and business texts are all communications under it. FINRA’s own guidance agrees — when Regulatory Notice 17-18 tells firms to retain text messages, the rule it cites is 17a-4(b)(4), not 4511.
None of which makes six years wrong, only misplaced — and SEA Rule 17a-4(a) does separately require it for certain books and records. Registered investment advisers are a different rulebook again. The window for each case is in the panel at the top of this page.
The arithmeticBasicNot viablePlan-dependent cap ProfessionalNot viablePlan-dependent cap EnterpriseThis is the tierUnlimited storage
A window you cannot delete inside, met by a plan that makes you delete
Run this before you pick a tier, because it is the only part of the decision that cannot be undone later without a records problem. A twenty-person firm recording every call accumulates continuously for the whole of the window, and no deletion is permitted inside it. Any plan with a storage cap eventually arrives at a fork.
A larger cap is a later date, not a different outcome. Recording every call is a rate of accumulation, and a rate meets any ceiling eventually.
The only one where the retention window decides when a record goes, rather than the storage bill deciding it first. Real-time analytics and a dedicated CSM are on it too.
Neither question ever comes up.Treat the quote itself as evidence.If a vendor quotes an entry plan to a regulated firm without asking a single question about retention, that is a signal about how well they understand your obligation — and you have learned it before signing rather than after.The actual caps on Basic and Professional are not published in our own product facts. Get the number in writing before you model anything on it, and see pricing for what each tier adds.
The part most vendor pages leave out
You will probably need a dedicated archiver as well as us
Preservation is a specialised function and most unified communications platforms, ours included, are not a substitute for it. Seven things have to happen for a regulated firm’s communications; three of them are ours, and being straight about the other four is worth more to you than a claim of turnkey compliance would be.
Rule 17a-4(f) now accepts either route
The original 1997 requirement, and still perfectly available. If your archiver is already WORM, nothing about the 2022 amendments obliges you to move.Added by the SEC’s amendments of 12 October 2022 — effective 3 January 2023, compliance date 3 May 2023. Two lawful routes now exist where vendor pages still describe one.
| What has to happen | DialPhone | An archiver | Your firm |
|---|---|---|---|
| Capture the call, the voicemail and the text in the first placeRecording on every call, from Professional up. | |||
| Make supervision review readable rather than replayableTranscription, so a reviewer reads a call instead of sitting through it. | |||
| Control who can open a record, and log who didAsserted and not yet documented — confirm the granularity before you rely on it for supervisory separation. | |||
| Preserve the record in the format the rule requiresA non-rewriteable, non-erasable format — nothing that lands can be altered afterwards. | |||
| File the undertakings that let a regulator get the recordsA designated third party, or since the amendments a designated executive officer with access to the records. | |||
| Decide which retention window applies to which recordThree-year communications, six-year default, five-year adviser — and which registrations you hold. | |||
| Confirm a channel can be retained before anyone is allowed to use itFINRA’s own wording: ensure you can retain the records first, then permit the channel. |
The common gap
The message that was never a record
This is where firms most often get caught, and it has nothing to do with storage tiers. A representative answers a client from the phone in their pocket, the client gets a perfectly good answer, and the firm acquires an obligation it has no way to meet.
Where the message actually went
FINRA puts these in an order, and the order is the requirement.Regulatory Notice 17-18 tells a firm that intends to permit its people to communicate about its business through a text messaging app or chat service to ensure first that it can retain records of those communications — citing SEA Rule 17a-4(b)(4) when it does. Retention capability comes before permission, not after the exam. 10DLC registration applies to the firm-issued side.Whether text messages are captured and retained alongside call records is not documented in our product facts. Confirm it before you move representative texting onto the platform on the strength of this page.
FAQ
Frequently asked questions
How long must call recordings be kept under FINRA and SEC rules?
For a broker-dealer, calls and voicemail are business communications under SEA Rule 17a-4(b)(4): not less than three years, the first two in an easily accessible place. FINRA Rule 4511(b)’s six years is the default for FINRA books and records that have no specified period elsewhere — it is not a blanket six years for everything, and communications already have a period.
So where does “six years” come from?
Two real places. FINRA 4511(b)’s catch-all, and SEA Rule 17a-4(a), which requires six years — first two easily accessible — for certain books and records. Neither is the communications rule. Plenty of firms adopt six years across the board as policy, which is a defensible decision; it is just worth making it as a decision rather than as a misreading.
We are a registered investment adviser, not a broker-dealer.
Then 17a-4 is not your rule. Advisers Act Rule 204-2 requires five years, the first two in an appropriate office of the adviser. A firm running both sides answers to both, and the longer obligation is the one that governs the shared system.
Does DialPhone make my firm FINRA compliant?
No, and no phone system does. It provides recording, transcription, storage and access controls. Compliance is your firm’s, and 17a-4 preservation typically requires a dedicated archiving vendor alongside it.
Do you support WORM or 17a-4 compliant archival?
Assume not without written confirmation, and plan for a dedicated archiving vendor. Note that since the SEC’s 2022 amendments there are two lawful routes — WORM, or a system that permits recreation of an original record if it is modified or deleted — so ask your archiver which one they are on.
Which plan do regulated firms need?
Enterprise, because unlimited storage is the deciding feature when deletion inside the retention window is not available to you. Rates are on pricing.
Are business text messages covered by the rules?
Yes. FINRA treats business texting as a business record, and Regulatory Notice 17-18 points at SEA Rule 17a-4(b)(4) for retention. Representatives texting clients from personal phones is the common supervision gap — see business SMS for what registration involves.
Can we restrict who accesses recordings?
Access controls are available. Confirm the granularity with support before relying on them for supervisory separation, and ask what the audit log records.
Can each branch have its own local number?
Yes. Local numbers and multi-site routing are on every plan.
Ask which window applies first.
Fourteen days, no card. Bring your compliance officer the record classes and the registrations you hold before you compare a single feature grid — the answer changes which tier you need, and it changes whether a phone system alone was ever going to be enough.
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