The Financial Industry Regulatory Authority issued guidance paralleling recent guidance issued by staff of the Securities and Exchange Commission that third-party recordkeeping services must grant access to a registrant’s required books and records, even if the registrant does not pay required fees. Any inapposite provision in a contract is prohibited. A recordkeeper that violates this could be subject to secondary liability for causing a registrant to violate its recordkeeping obligations. (Click here for background on the SEC’s guidance in the article “SEC Confirms Third-Party Recordkeeping Retention Agreements That Provide for Deletion or Discarding Documents in Case of Broker-Dealer Non-Payment Are Not Permitted” in the April 15, 2018 edition of Bridging the Week.)