Would like to ask if anyone has a specific procedure in place for ensuring the recordkeeping requirements are met for NDP (in the bank)? In our bank, we have a "folder" where agreements, copies of licenses, training, etc. are kept but a problem has come up recently as to who should really be the person responsible for maintaining this folder. As the compliance officer I have not been doing so since I need to monitor this from time to time so it has floated around to a few folks. Just wondered if anyone else does something similiar? Thanks.

I take it from your questions that you are dealing with more than one individual. If that is true, are one of the persons involved in your NDP program licensed as a "principal"? My first inclination would be that the information you describe might be necessary for the principal to fulfill his/her obligations. My second thought is that your HR department might be an appropriate place to hold the information. The records you speak of appear to fall into what I consider personnel records.

Thank you for your comments. Yes we have several individuals who are "dual employees". Our principal indicates that he cannot retain this info as it would be conflict of interest. Not really sure this is considered personnel records as some of the documentation is agreements between the brokerage company and the bank, sales/incentive records, etc. Can't find a good home for this so I just wondered what other folks were doing.