Geoffrey Richards Securities of Hypoluxo, FL, came up $25,000 short in its efforts to comply with FINRA rules for business-related electronic communications.  FINRA acknowledged that the firm attempted to preserve such communications by burning them to a non-rewriteable, non-erasable disc each month.  However, the process was deficient because it didn't result in all such communications being saved to the disc. The firm further compounded the problem by not identifying this deficiency in its audit of its e-communications preservation system. 

The firm also, in contravention of its WSP's, permitted RR's to use outside or non-firm-sponsored email accounts to send and receive securities business-related emails.  The firm’s preservation process did not capture these emails that were sent to or from those accounts - thus, these emails allegedly were neither retained nor reviewed. 

FINRA also found that the firm relied exclusively on electronic storage media to preserve its business-related e-communications, but did not retain a 3rd party who had the access or ability to download information from its electronic storage media. 

Geoffrey Richards will pay a $25K fine.   This is FINRA Case #2009015971101.   [Disciplinary Actions for June 2011]