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One hopes they would but one has one's suspicions that the economy of doing nothing is more attractive. Short termism I think! Sue From: Marc Fresko [mailto:[log in to unmask]] Sent: 30 December 2013 17:00 To: Sue Hill; [log in to unmask] Subject: RE: FINRA Fines Barclays $3.75M for Systemic Record and Email Retention Failures - WSJ.com Brilliant Sue, I love it. $600k/year is indeed good value when you look at it that way. But the problem with that analysis is that Barclays will now have to do something - at great expense - for future years. If they don't, fines much greater than $600k/year can be expected, don't you think? Marc PS If you read the detailed FINRA report, you'll find "in determining the appropriate sanction, FINRA considered that [Barclays Capital] self-reported the issues described...", implying that Barclays chose to report the issue to FINRA and that a higher penalty would have been applied had the non-compliance been found out in some other way. From: The Information and Records Management Society mailing list [mailto:[log in to unmask]] On Behalf Of Sue Hill Sent: 30 December 2013 16:46 To: [log in to unmask]<mailto:[log in to unmask]> Subject: FINRA Fines Barclays $3.75M for Systemic Record and Email Retention Failures - WSJ.com Further to Peter K's email $3.75 m is cheap at the price. The period quoted is about 6 years = just over $600k per year The cost of a team of RMs, some executive time, a project manager or two, the planning time, rental for the space where they sit, software to use, etc etc is probably more per annum than that. So were they careless or did they simply do a Risk Management Assessment and decide it was the better option to do nothing? Sue (Always with an eye on how management view the cost of hiring staff and their excuses to not spend it!!) PS - Hot news! SHR is now part of the Progility Plc group. Read more at bit.ly/1aDn3FN <http://t.co/uzuH83fNic> ++++++++++++++++++++++++++++++++++++++ Sue Hill FIRP Hon FCLIP Hon FCDG Sue Hill Recruitment - Blogging on http://suehill.typepad.com/ and tweeting on @SueHillRec Borough House 80 Borough High Street London SE1 1LL Tel 020 7378 7068 Mobile 07973 543 704 Registered Office: 2nd Floor Strand Bridge House 138 - 142 The Strand London WC2R 1HH Registered in England No. 3484222 VAT No. 709 9652 93 ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ Date: Sun, 29 Dec 2013 09:41:14 -0600 From: PeterK <[log in to unmask]<mailto:[log in to unmask]>> Subject: FINRA Fines Barclays $3.75M for Systemic Record and Email Retention Failures - WSJ.com FINRA Fines Barclays $3.75M for Systemic Record and Email Retention Failures - WSJ.com FINRA also found that from May 2007 to May 2010, Barclays failed to properly retain certain attachments to Bloomberg emails, and additionally failed to properly retain approximately 3.3 million Bloomberg instant messages from October 2008 to May 2010. In addition to violating FINRA, SEC and NASD rules and regulations, this adversely impacted Barclay's ability to respond to requests for electronic communications in regulatory and civil matters. Finally, Barclays failed to establish and maintain an adequate system and written procedures reasonably designed to achieve compliance with SEC, NASD, and FINRA rules and regulations, as well as to timely detect and remedy deficiencies related to those requirements. http://on.wsj.com/19xnulQ Source: http://online.wsj.com/article/BT-CO-20131226-703041.html See if people are clicking on this link: http://on.wsj.com/19xnulQ+ Try the bitly.com sidebar to see who is talking about a page on the web: http://bitly.com/pages/sidebar For any technical queries re JISC please email [log in to unmask]<mailto:[log in to unmask]> For any content based queries, please email [log in to unmask]<mailto:[log in to unmask]> To view the list archives go to: https://www.jiscmail.ac.uk/cgi-bin/webadmin?A0=RECORDS-MANAGEMENT-UK To unsubscribe from this list, send an email to [log in to unmask] with the words UNSUBSCRIBE RECORDS-MANAGEMENT-UK For any technical queries re JISC please email [log in to unmask] For any content based queries, please email [log in to unmask]