The migration to Atlassian Cloud for financial services is more than an IT upgrade; it is a wholesale transfer of "institutional memory." Today, Jira and Confluence act as the central nervous systems for trade algorithm changes, compliance incident tracking, and listing committee decisions.
However, a fundamental friction exists between cloud agility and federal law. While the cloud is built for fluid change, SEC Rules 17a-1 and 17a-4 demand permanence. For Self-Regulatory Organizations (SROs) and broker-dealers, the challenge isn't just storing data, it's ensuring that data remains an unshakeable, legible record of truth.
A common misconception in the transition to SaaS is that a data export equals compliance. Most platforms fulfill data portability requirements by providing raw JSON or XML blobs. Does Atlassian’s native backup satisfy SEC Rule 17a-4’s "human-readable" requirement? Not natively. While technically "data," these files are structurally complex and divorced from their context.
The SEC addressed this "Black Box" risk in its 2022 amendments to Rule 17a-4. Under paragraph (j), firms are now explicitly mandated to furnish records in a "human-readable and reasonably usable electronic format." (Source: SEC)
To remain compliant, firms must be able to transform abstract metadata into navigable dossiers, like HTML or PDF, which can be reviewed by an auditor without a computer science degree.
Atlassian operates under a Shared Responsibility Model: they guarantee the platform's uptime, but you are responsible for the integrity of the data within it. What is the "Resilience Gap" in the Shared Responsibility Model? It is the liability created when native cloud limitations meet statutory requirements. This gap becomes a crisis in several scenarios:
SEC Rule 17a-1 serves as the "institutional memory" mandate for Self-Regulatory Organizations (SROs), requiring them to preserve "all documents" made or received in the course of their business for a minimum of five years. In a cloud environment like Atlassian, this creates a significant compliance risk because native "trash" settings often permanently purge deleted projects or tickets after only 30 days. To avoid federal violations, SROs must implement third-party archiving solutions that bridge the gap between Atlassian’s mutable cloud and the five-year immutable retention required by law.
(Source: ECFR)
Yes. Paragraph (j) of SEC Rule 17a-4 explicitly mandates that firms must furnish records in a "human-readable and reasonably usable electronic format" upon request. For Jira and Confluence users, this means that providing raw database backups or complex JSON/XML exports may not suffice during an examination. To remain compliant, firms must have the capability to transform technical metadata into legible, searchable dossiers, such as linear PDF or HTML reports, that allow an examiner to review the history of a ticket or a configuration change without requiring specialized programming knowledge.
Yes, but with a major technical caveat. To satisfy the SEC's audit trail mandate, the system must capture the identity of the person making a change, the specific time of the action, and every interim iteration of the record.
The risk for many firms is that native Atlassian audit logs are not designed for long-term legal preservation. They often have limited retention windows, sometimes as short as 180 days, meaning your "proof of integrity" could roll over and disappear years before your 5-to-10-year retention mandate is up. To bridge this gap, Revyz offloads these logs into a tamper-proof, air-gapped environment, ensuring they remain immutable and accessible for the entire statutory lifecycle.
(Source: SEC)
Yes. SEC Rule 17a-4(i) mandates that any third party (such as a cloud provider or backup vendor) maintaining a broker-dealer's regulatory records must file a written undertaking with the SEC. Following the 2022 amendments, a specialized "Alternative Undertaking" is permitted for cloud service providers, provided the firm maintains "independent access" to its records without the provider's intervention. Revyz satisfies this by storing data in a customer-controlled, air-gapped AWS environment, ensuring the firm retains the ability to search, retrieve, and produce records independently of the live Atlassian instance.
In a mutable cloud environment, permanence is not a native feature, it is a strategic choice. Revyz acts as a” compliance center”, providing the "Digital Air Gap" necessary to satisfy global regulators through:
The "Cost of Inaction" is no longer theoretical; it is a line item in recent enforcement results. In fiscal year 2024, the Commission brought recordkeeping cases resulting in more than $600 million in civil penalties against more than 70 firms, including the Commission’s first cases charging recordkeeping violations against municipal advisors.
By closing the Resilience Gap, financial institutions move from "trusting the vendor" to "verifying the data," effectively insuring their license to operate in the cloud.