Bukenya then reviews Jacaranda’s record-keeping policy. Currently, the policy requires retention of hard copies of all supporting documentation for investment recommendations and decisions made during the last five years. This policy meets the new risk-based regulations. Client meeting minutes and communication logs are kept electronically and backed up on a remote server. Fund managers and research analysts are responsible for maintaining their own personal notes and research models. This policy also applies to Jacaranda’s independent research contractor, Mathew Ochieng, who (for security reasons) does not have access to the company’s server. Ochieng, who only undertakes research for Jacaranda, sends his research reports to the head of research, who then archives these electronic copies.
Does Bukenya’s confidentiality policy most likely violate Standard III(E)–Preservation of Confidentiality?
A.
No.
B.
Yes, with regard to type of information.
C.
Yes, with regard to client status
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