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Legal Holds

Firmly enables investment firms to preserve data during SEC examinations, investor litigation, regulatory inquiries, or internal compliance reviews. Holds can target all data for a firm or specific deal conversations and documents. Protected data is excluded from automated retention cleanup until the hold is released.

Why Legal Holds Matter in Investment Management

Investment firms face unique legal preservation requirements:

  • SEC examinations may require preserving all records related to specific investment activities or time periods
  • Investor litigation may require preserving all communications and documents related to a fund or investment
  • FINRA inquiries may require preserving records related to specific transactions or personnel
  • Internal compliance reviews may require preserving records while investigating potential violations

Firmly's legal hold system ensures that relevant data is preserved regardless of normal retention policies.

Supported Hold Reasons

  • Litigation — Investor lawsuit, breach of fiduciary duty claim, or other civil litigation
  • Regulatory investigation — SEC examination, FINRA inquiry, state securities regulator investigation
  • Subpoena — Court-ordered or regulatory production of investment records
  • Internal investigation — Compliance review, trading investigation, conflict of interest inquiry

What Can Be Preserved

Holds can protect any combination of:

  • Audit logs — Records of investment data access
  • Investment conversations — AI-assisted discussions about deals and portfolio
  • Deal documents — Term sheets, models, due diligence materials, research

Holds can be broad (all data for a firm) or targeted (specific deal conversations or documents), allowing you to preserve only what's relevant while normal retention continues for unrelated data.

Hold Lifecycle

  1. Creation — Hold is created with documented reason, scope, and optional expiration
  2. Active — Protected data is excluded from all retention cleanup
  3. Release — Hold is released with documented reason; data becomes eligible for normal retention

All hold operations are recorded in the tamper-evident audit trail.

Investment Scenarios

SEC Examination

When your firm receives an SEC examination notice, create a legal hold targeting all conversations and documents related to the examination scope. Include audit logs to preserve the record of who accessed what information. Maintain the hold until the examination concludes and any follow-up period expires.

Investor Litigation

When served with an investor complaint, create a hold on all data related to the fund or investment at issue. Preserve all communications, deal documents, and access logs that may be relevant to the dispute.

Trading Review

When reviewing potential trading violations, create a targeted hold on conversations involving the relevant personnel and time period. Preserve audit logs showing their access patterns. Release after review concludes with documented findings.

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