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FINRA

FINRA (Financial Industry Regulatory Authority) cybersecurity rules govern broker-dealers and financial services firms. Key regulations include SEC Rule 17a-4 (electronic recordkeeping), Regulation S-P (privacy), Regulation S-ID (identity theft), and FINRA Rules 3110 (supervision) and 4370 (business continuity).

Capsule provides protocol-level capabilities that address recordkeeping integrity, record authenticity, and supervisory audit requirements.


SEC Rule 17a-4: Electronic Recordkeeping

Requirement How Capsule Addresses It
Records must be preserved in non-rewriteable, non-erasable (WORM) format Capsules are sealed with SHA3-256 + Ed25519 at the moment of action. Any modification changes the hash and invalidates the signature. Hash chain makes the record sequence tamper-evident.
2 years of immediately accessible records; 3-6 years archive Capsules are persisted in SQLite or PostgreSQL with configurable retention. storage.list() provides paginated retrieval.
Records must be indexed and searchable Capsules are queryable by type (CapsuleType), time range, tenant, session, and chain position.

Record Authenticity (REC-2)

Requirement How Capsule Addresses It
Digital signatures to verify record origin Ed25519 signature on every Capsule with signed_by key fingerprint. Optional ML-DSA-65 (FIPS 204) post-quantum dual signature.
Hash verification to detect unauthorized modification SHA3-256 content hash. seal.verify(capsule) recomputes the hash from content and compares to the stored hash.
Audit trails to detect unauthorized modifications Hash chain links each Capsule to the previous via previous_hash. chain.verify() detects any modification, deletion, or insertion in the sequence.

FINRA Rule 3110: Supervision

Requirement How Capsule Addresses It
Written supervisory procedures Authority section records authorization type (autonomous, human_approved, policy, escalated), policy references, and approval chains.
Review of supervisory activities Capsules are structured, machine-readable records. Reasoning section captures pre-execution deliberation for supervisory review.
Evidence of supervision Each Capsule's Authority section documents who or what approved the action and why escalation occurred (if applicable).

Complementary Controls

The following FINRA requirements are outside the protocol's scope:

  • Reg S-P Customer data privacy -- application-level data handling
  • Reg S-ID Identity theft prevention -- application-level identity management
  • Rule 4370 Business continuity planning -- organizational
  • WORM storage enforcement -- Capsule provides tamper-evidence at the protocol layer; WORM storage enforcement is a deployment-level concern (e.g., S3 Object Lock, immutable storage)

Back to Compliance Overview