Complaint Process – Exchange Act Rule 17a-3(a)(18)(ii)

Books and Records (Exchange Act Rules 17a-3 and 17a-4; FINRA Rule 4500 Series):

Exchange Act Rule 17a-3 identifies the types of books and records that OPM must keep. Exchange Act Rule 17a-4 defines how long these books and records must be kept. (SROs also specify certain recordkeeping requirements; see next section.) OPM’s Designated Principals have responsibility for retaining required records for areas under their supervision. The FINOP is responsible for establishing OPM’s record retention schedule. The FINOP will have remote access to the Company’s books and records. The System used to prepare monthly financial statements (i.e., manual or electronic books and records package program, outside software, or proprietary accounting system) will be QuickBooks. The CCO will be responsible for ensuring that records will be maintained in an easily accessible location at least the first two years. Additionally, per the amended Form BR, OPM will report any location where books and records for a registered branch office are maintained in addition to the address of the registered branch office, the main office or, if applicable, the OSJ designated to supervise the registered branch office. OPM will update the Form BR with the address of this location and the name and telephone number of a contact person.