# Exam-Ready Case Management for SEC & FINRA Compliance

Turn flagged messages into a defensible case record. Comma links evidence, custodians, and policies, then exports a complete, producible record for exams.

Source: https://commacompliance.com/exam-ready-cases
Last updated: 2026-08-14

---

Case Management

# From Scattered Screenshots to a Defensible Record

A complete record, from the first flag to the final export.

Comma turns flagged messages into structured cases, with evidence, custodians, and policies linked to each one. When regulators ask, export the complete record with evidence and audit trail included.

[Get in touch](/get-in-touch)

*Image: Comma case Regulatory panel showing a recorded reportability decision: Reportable event, logged by Priya Raman under FINRA Rule 4530*

## Disconnected Evidence Doesn’t Hold Up

Managing compliance cases through screenshots and shared spreadsheets is slow, hard to search, and hard to defend when an examiner asks for the record.

Comma replaces that with a single, review-ready case record, linked to the evidence behind it.

## From Flag to Defensible Record

Every flagged message, archived conversation, or team contact can become a case, and every case carries the context that makes it defensible later. The path follows the way supervision already runs.

1.  ### Open a case from anywhere

    From a policy-matching flag, an archived message, or a team contact, start a new case or add the item to an existing one. Either way, the evidence stays linked from the start, so the case remains complete as the investigation evolves.

2.  ### Link evidence, custodians, and policies

    Connect the related messages, the custodians involved, and the policies in play, and assign a status so the case stays organized as it moves.

3.  ### Record the reportability decision

    For FINRA-supervised firms, every case carries a regulatory panel. Log a reportable event under Rule 4530, or record a reasoned decision not to file, with the basis and the person who made the call. The decision not to report is a record too, and examiners ask about both.

4.  ### Preserve records when a matter needs it

    When a matter may require regulatory reporting or litigation support, place the case under a legal hold so the communications it depends on are preserved. Supports retention workflows aligned with SEC Rule 17a-4, including WORM-compliant recordkeeping.

5.  ### Export a complete, producible record

    Close the case with a documented resolution, then export the full record when regulators ask.

*Image: Off-channel review case detail in Comma: policy triggered, a reportability decision recorded under FINRA Rule 4530, the linked source WhatsApp message, and a timestamped activity timeline.*

A case opened from a flagged WhatsApp message. The triggering policy, the reportability decision, the source evidence, and a timestamped activity trail, all in one record.

✕

*Image: Off-channel review case detail in Comma: policy triggered, a reportability decision recorded under FINRA Rule 4530, the linked source WhatsApp message, and a timestamped activity timeline.*

## Every Open Matter in One View

You’re running surveillance across the firm, managing internal reviews, and responding to external exams, often all at once. The Cases dashboard shows what’s open, who owns it, and where it stands.

*Image: Comma Cases dashboard listing open compliance cases with status, resolution, owner, and date*

Open cases, with status, resolution, owner, and date.

✕

*Image: Comma Cases dashboard listing open compliance cases with status, resolution, owner, and date*

## What’s in Every Case Record

Every case combines the evidence, activity, and decisions needed to explain what happened and demonstrate how it was handled.

-   Linked evidence: the messages, files, and conversations the case is built on
-   Activity timeline: a timestamped record of what was done, and by whom
-   Custodians: the people whose communications are in scope
-   Policies: the rules the case was matched against
-   Reportability decision: the FINRA Rule 4530 call, including the reasoned basis when a firm decides not to file
-   Preservation status: whether the case is under a legal hold
-   Resolution: the documented outcome, from policy update to training notice
-   Write-once (WORM) storage, aligned with SEC Rule 17a-4 recordkeeping

For FINRA-supervised firms, the firm identity and filing contact that a Rule 4530 filing has to carry are set once in Configuration and travel with every filing pack. See [Firm identity and filing contact](https://docs.commacompliance.com/settings/regulatory-reporting/#firm-identity--filing-contact) in the docs.

## Producible on Demand

Every exam eventually comes down to the same question: can you produce the complete record? Because each case links its evidence, activity trail, and resolution as the work happens, the record is assembled long before anyone asks for it. Producing it is a routine step rather than a scramble across screenshots and spreadsheets, and what you hand over matches what your team actually reviewed.

### What happens when records can’t be produced

178

Off-channel communication breaches identified across 11 firms in a single FCA review.UK, Financial Conduct Authority (2025)

HK$10.85M

Fine after a firm failed to produce due diligence records for 141 bonds during an SFC inspection.Hong Kong, Securities and Futures Commission (2025)

$10.3M

Fines, costs, and disgorgement issued through CIRO enforcement, supported by its dedicated evidence and eDiscovery unit.Canada, CIRO (2025)

## FAQ about Exam-Ready Cases

How does a flagged message become a case?

When policy matching flags a message, you open a case directly from it. The triggering message and the policy it matched come with it, and you link the related evidence, custodians, and policies from there. The case becomes the record of what was reviewed, by whom, and how it was resolved.

Can I produce a complete record for an exam?

Yes. Every case can be exported as a complete record, with its linked evidence, timeline, and resolution. The point is to make production a routine step rather than a fire drill when a regulator asks.

Can Comma record a decision not to report an event?

Yes. For FINRA-supervised firms, every case carries a regulatory panel. You log a reportable event under Rule 4530, or you record a reasoned decision not to file, with the basis and the person who made the call. Both are part of the case record. Comma records the decision, drafts the quarterly complaint statistics, and reminds your admins of deadlines. Reviewing, approving, and filing with FINRA stay with your firm.

What is a custodian in Comma?

A custodian is a person of interest in a case, someone whose communications are in scope for a review, a preservation, or an exam. Linking custodians to a case keeps the record organized around the people a matter actually concerns.

## See what a defensible record looks like.

Talk to our team about how compliance groups turn continuous supervision into a complete, producible record across every channel they capture.

[Get in Touch](/get-in-touch)[Pricing](/pricing)

Explore what else Comma can do

## Built end-to-end for regulated communications

### [Messaging Archival](/compliance-archiving)

40+ channels captured automatically. Business messages separated from personal.

See archiving →

### [Policy Matching](/policy-matching)

Continuous supervision that flags the messages carrying risk and samples the rest, across every channel you capture.

See policy matching →

### [Encrypted Messaging Compliance](/encrypted-messaging-compliance)

Why mobile channels are where exam risk lives, and what compliant capture actually requires.

Read more →
