As such, Omgeo TradeSuite Confirm Archive is now available to all TradeSuite clients.

The first letter was issued on March 19, 2009 and permits Omgeo to maintain and preserve confirmations for broker-dealers participating in its TradeSuite service in satisfaction of Securities Exchange Act Rules 17a-3 and 17a-4.

The second letter was issued on August 14, 2009 and permits Omgeo to maintain and preserve confirmations on behalf of investment advisers that participate in its TradeSuite service in satisfaction of Investment Advisers Act Rules 204-2(a)(7), 204-2(b)(3), and 204-2(g).

In an effort to streamline the archiving process and eliminate redundant effort, Omgeo petitioned the SEC for the no-action letters to allow both buy- and sell-side firms participating in Omgeo TradeSuite to outsource their confirmation recordkeeping obligations under the federal securities laws to Omgeo. The TradeSuite Confirm Archive service essentially replaces clients' current confirm storage method with an online self-service system, which reduces risk and cost, as well as streamlines processes across the industry.

The TradeSuite Confirm Archive service is web-based, so no implementation or testing is necessary. This solution was built with input from Omgeo's 10b-10 working group. Once enabled, TradeSuite clients have access to seven years of electronic confirmations and can access the functionality as soon as they receive a username and password. The service is built on DTCC's PBS SMART/Search application, allowing clients to access the Confirm Archive service under Omgeo Reports. The reports can be accessed based on a wide variety of search criteria, for example, institution ID and report date, among others.

Omgeo has been working with its client community, industry associations and the SEC over the past two years to reduce the use of paper needed to meet SEC requirements. Omgeo's 10b-10 working group provided input to Omgeo as the TradeSuite Confirm Archive service was developed. Both the TradeSuite Confirm Archive service and Confirm Disclosure service (announced April 2008) eliminate wasteful paper associated with trade confirmations. These moves dramatically reduce the tremendous cost and inefficiencies associated with large amounts of paper, storage fees and postage.

"We are extremely appreciative to receive this no-action letter from the SEC," said Lee Cutrone, managing director, industry relations at Omgeo. "Because of this, Omgeo can now take the administrative and regulatory aspects of confirm archiving off our clients' plates. Users will no longer have to concern themselves with confirmation archiving, as Omgeo will handle the entire process seamlessly and in real-time. Redundant and costly measures are particularly burdensome in today's market so we are pleased that the SEC recognizes Omgeo TradeSuite Confirm Archive service as a means to streamline the industry."