With internal control functions attenuated with distance, the potential that careful record-keeping gets neglected is an invitation to significant liability.

Regulated entities such as registered investment advisers are obligated to maintain accurate copies of certain books and records relating to their investment advisory business in order to permit “easy location, access, and retrieval of any particular record,” pursuant to Section 204 of the Advisers Act and Rule 204-2 thereunder, and to make them available to the SEC, including its examination staff, for inspection.