In October 2014, 15 financial institutions created a cloud-based financial messaging platform, known as Symphony Communications Services LLC, to allow for secure communications between them. Regulators, including the New York Department of Financial Services, became concerned that Symphony’s encryption and privacy settings would prevent investigators from catching improper trading activities. However, on September 14, 2015, the DFS announced that Goldman Sachs Group Inc., Deutsche Bank AG, Credit Suisse and Bank of New York Mellon Corp., the four banks directly regulated by New York State, had agreed to strict document retention requirements, including to retain copies of electronic communications between them for seven years and to store duplicate copies of encryption keys for custodians not controlled by those banks. The banks have been lauded for their cooperation and those that could be reached for comment expressed satisfaction at having been able to reach the agreement.
