The Securities and Exchange Commission (SEC) Rule 17a-4 describes stringent rules that govern the storage of all electronic messages including e-mail and instant messages for its members. To comply with Rule17a-4, customers must weigh the cost of installing a dedicated e-mail archive server versus the alternatives. Alternatives include using an existing message server (MS Exchange or IBM Lotus Notes typically), using a backup server or using a Hierarchical Storage Manager (HSM) server. In this article we will compare the basic functionality of each of these alternatives to the requirements of SEC Rule 17a-4.
E-mail message server
The first alternative is to simply use the existing message server for archival. The message server stores original records and makes them accessible by authorized persons. The records are searchable in their header and body and the index of the records is maintained for the life of the record. The message server falls short of SEC Rule 17a requirements by not storing the records on "unalterable" media, it does not make duplicates of the records, and it does not audit activity in the message store. Depending on the number of users and the number of e-mails per day, the size of the e-mail server can quickly grow. This creates new potential problems such as longer backup times, longer recovery times and demand for more storage.
Backup server
Many customers are tempted to use the backup server and the backup tapes it creates to comply with SEC Rule 17a-4. While the backup server creates copies of all the original records, it fails in many other key areas. The backup server does not typically store records to unalterable WORM media, although this is technically possible. The backup server also does not create an index that can be searched and used to retrieve records and the backup server does not audit all activity in the message store. The temptation to use the backup server for e-mail archival can be particularly painful if your company is required by a legal discovery request to retrieve e-mail records from tape. How long would it take (and cost) your company to search multiple years of backup tapes for certain keywords in e-mail messages?
HSM server
Hierarchical Storage Manager (HSM) applications are a popular method for reducing the load on the message server. It is widely known that by moving attachments from the message server to secondary storage, the storage demand on the message server can be reduced by over 50%. While HSM works well for this purpose, it fails to comply with SEC Rule 17a-4. HSM does not create an index that can be searched to retrieve records. HSM does not make copies of the records and it does not audit all activity in the message store.
Dedicated e-mail archive server
In 1999 KVS Inc. and Educom TS Inc. introduced the first dedicated e-mail archive solutions. Other companies have since entered this market. A primary function of these solutions is to archive e-mail messages onto media that is "non-erasable" and "non-rewriteable". In addition, these solutions create an index that is used to search and retrieve e-mail records. Using a search tool, users can perform complex searches of the entire e-mail archive database, retrieving e-mails required for SEC investigations and other possible legal discovery requests. The e-mail archive server makes duplicates of the e-mail records, duplicates of the index and only allows authorized access to the e-mail archive. An audit log of the e-mail archive tracks each and every action that is performed on the archive. If necessary, a SEC investigator can review all activity in the archive and determine if any wrong doing has occurred. (See Table 1)
Conclusion
When you weigh the cost of a dedicated e-mail archive server versus the cost of struggling to comply using one of the alternatives, the benefits of an e-mail archive server are evident. The unique features that SEC Rule 17a-4 requires are not found in any other pre-existing application in their entirety. A dedicated e-mail archive will allow you to manage the size of your message server and maintain higher service levels. Furthermore, an e-mail archive server is designed to perform complex searches and retrievals – tasks that can be performed in hours as compared to days and weeks. A single court request that may force you to manually load, read and search thousands of backup tapes, alone can validate the cost of an e-mail archival system.
About the author:
Bob Spurzem is a Principal Analyst with Contoural Inc. an independent provider of storage consulting and storage education services. He has been closely involved in the storage industry for the six years as a Product Marketing Manager with leading storage software vendors.
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