📜 DOCUMENT RETENTION POLICY
Field | Value |
|---|---|
Document ID | OTCM-POL-DRP-001 |
Version | 1.0 |
Effective Date | January 30, 2026 |
Classification | CONFIDENTIAL |
Approved By | Board of Directors |
📋 TABLE OF CONTENTS
- Article I: Purpose and Scope
- Article II: Definitions
- Article III: Document Retention Schedule
- Article IV: Blockchain and Digital Asset Records
- Article V: Electronic Records Management
- Article VI: Litigation Hold Procedures
- Article VII: Document Destruction
- Article VIII: Responsibilities
- Article IX: Compliance and Enforcement
- Article X: Administration
🎯 ARTICLE I: PURPOSE AND SCOPE
Section 1.1 — Purpose
This Document Retention Policy (the "Policy") establishes standards and procedures for the retention, preservation, and destruction of Company records. The Policy is designed to:
🎯 Objective | Description |
|---|---|
⚖️ Legal Compliance | Ensure compliance with legal and regulatory retention requirements |
🛡️ Litigation Protection | Protect the Company in actual or potential litigation |
📊 Business Continuity | Support business operations and historical reference |
🔐 Data Security | Protect sensitive and confidential information |
💾 Storage Efficiency | Manage storage costs and information overload |
🔗 Blockchain Integrity | Preserve immutable blockchain records appropriately |
Section 1.2 — Regulatory Framework
This Policy is adopted pursuant to and in compliance with:
⚖️ Regulation | Retention Impact |
|---|---|
Securities Exchange Act of 1934 | Broker-dealer and transfer agent records |
SEC Rules 17a-3, 17a-4 | Books and records requirements |
SEC Rules 17Ad-6, 17Ad-7 | Transfer agent recordkeeping |
Sarbanes-Oxley Act | Audit workpapers, financial records |
IRS Code Section 6001 | Tax records |
ERISA | Employee benefit records |
Wyoming Business Corporation Act | Corporate records |
SEC January 2026 Guidance | Tokenized securities records |
Section 1.3 — Scope
This Policy applies to all records created, received, or maintained by the Company, including:
📁 Record Type | Examples |
|---|---|
📄 Paper Documents | Contracts, certificates, correspondence |
💻 Electronic Files | Emails, spreadsheets, databases, presentations |
🔗 Blockchain Records | Smart contracts, transaction logs, wallet data |
🎥 Media | Audio, video, photographs |
💬 Communications | Instant messages, text messages, voicemails |
☁️ Cloud Data | SaaS applications, cloud storage |
📖 ARTICLE II: DEFINITIONS
Section 2.1 — Key Definitions
📄 "Record"
Any information, regardless of physical form or characteristics, created, received, or maintained by the Company in the conduct of its business, including documents, data, and blockchain entries.
🔗 "Blockchain Record"
Any data stored on a distributed ledger, including smart contract code, transaction hashes, wallet addresses, token transfers, and metadata associated with ST22 Security Tokens or OTCM Utility Tokens.
⚖️ "Litigation Hold"
A directive to preserve all documents and records potentially relevant to pending, threatened, or reasonably anticipated litigation, government investigation, or audit.
📁 "Record Custodian"
The department or individual responsible for maintaining and managing specific categories of records.
🗑️ "Destruction"
The permanent elimination of records through shredding, incineration, deletion, or other means that render the record unreadable and unrecoverable.
💾 "Active Record"
A record currently in use or referenced frequently for business operations.
📦 "Inactive Record"
A record no longer needed for daily operations but retained for legal, regulatory, or historical purposes.
🔒 "Permanent Record"
A record that must be retained indefinitely due to legal requirements, historical significance, or ongoing business value.
📅 ARTICLE III: DOCUMENT RETENTION SCHEDULE
Section 3.1 — Corporate Records
📁 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
🏛️ Articles of Incorporation | Permanent | Including all amendments |
📜 Bylaws | Permanent | Including all amendments |
📋 Board Minutes | Permanent | All board and committee meetings |
🗳️ Shareholder Meeting Minutes | Permanent | Annual and special meetings |
📊 Stock Ledger | Permanent | All ownership records |
📄 Stock Certificates | Permanent | Issued and cancelled |
🏷️ Assumed Name Certificates | Permanent | DBA filings |
📝 Annual Reports to State | Permanent | All jurisdictions |
✅ Board/Committee Resolutions | Permanent | All formal resolutions |
📋 Shareholder Consents | Permanent | Written consents in lieu of meeting |
Section 3.2 — Financial Records
📁 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📊 Annual Financial Statements | Permanent | Audited statements |
📈 Quarterly Financial Statements | 7 years | Internal and external |
📒 General Ledger | Permanent | All entries |
💳 Accounts Payable Records | 7 years | Invoices, payment records |
💰 Accounts Receivable Records | 7 years | Invoices, collection records |
🏦 Bank Statements | 7 years | All accounts |
✅ Bank Reconciliations | 7 years | Monthly reconciliations |
🧾 Expense Reports | 7 years | Employee reimbursements |
📋 Budgets | 5 years | Annual budgets |
🔍 Audit Reports | Permanent | Internal and external |
📊 Audit Workpapers | 7 years | Per SOX requirements |
Section 3.3 — Tax Records
📁 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📋 Income Tax Returns | Permanent | Federal and state |
📊 Tax Workpapers | 7 years | Supporting documentation |
💰 Payroll Tax Returns | 7 years | All filings |
🧾 Sales Tax Returns | 7 years | All jurisdictions |
📄 1099 Forms Issued | 7 years | Information returns |
📝 W-2 Forms | 7 years | Employee wage statements |
🏢 Property Tax Records | Permanent | Assessments and payments |
📋 Tax Exemption Documents | Permanent | Certificates and rulings |
Section 3.4 — Employment Records
📁 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
👤 Employee Personnel Files | 7 years after termination | General employment records |
📋 I-9 Forms | 3 years after hire or 1 year after termination (longer) | Immigration verification |
💰 Payroll Records | 7 years | Wages, deductions, hours |
🏥 Benefits Records | 7 years after plan termination | ERISA requirement |
📊 Performance Reviews | 5 years after termination | Evaluations |
⚠️ Disciplinary Records | 7 years after termination | Warnings, actions |
🏆 Training Records | 5 years after termination | Certifications, completions |
📝 Employment Applications | 3 years | Hired and not hired |
🔒 Background Check Records | 5 years | Per FCRA |
📋 OSHA Records | 5 years | Injury/illness logs |
Section 3.5 — Contracts and Legal
📁 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📜 Executed Contracts | 10 years after expiration | All material contracts |
🏢 Real Estate Documents | Permanent | Deeds, leases, mortgages |
📋 Intellectual Property | Permanent | Patents, trademarks, copyrights |
⚖️ Litigation Files | 10 years after final resolution | All legal matters |
📝 Settlement Agreements | Permanent | All settlements |
🔒 NDAs/Confidentiality Agreements | 10 years after expiration | Non-disclosure agreements |
📄 Insurance Policies | Permanent | All policies |
💳 Insurance Claims | 10 years after settlement | Claims and correspondence |
📋 Licenses and Permits | Permanent | Current and expired |
⚖️ Legal Opinions | Permanent | Outside counsel opinions |
Section 3.6 — Securities and Regulatory Records
📁 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📊 SEC Filings | Permanent | All forms filed |
📋 Form D Filings | Permanent | Reg D exemption notices |
📜 Private Placement Memoranda | Permanent | Offering documents |
✅ Subscription Agreements | Permanent | Investor subscriptions |
👤 Accredited Investor Verification | 7 years | Documentation of status |
📊 Cap Table Records | Permanent | All ownership records |
📋 Investor Communications | 7 years | Reports, notices |
🔒 Insider Trading Records | 7 years | Pre-clearance, blackout |
📄 Related Party Transaction Records | 7 years | Approvals, documentation |
📊 Section 16 Filings | Permanent | Forms 3, 4, 5 |
🔗 ARTICLE IV: BLOCKCHAIN AND DIGITAL ASSET RECORDS
Section 4.1 — Immutable Blockchain Records
⚠️ IMPORTANT: Blockchain records are inherently immutable and cannot be deleted. This Policy addresses the retention of related off-chain records and metadata.
🔗 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📜 Smart Contract Source Code | Permanent | All deployed contracts |
🔍 Smart Contract Audits | Permanent | Security audit reports |
📊 Deployment Records | Permanent | Transaction hashes, addresses |
🔧 Contract Upgrade History | Permanent | All modifications |
Section 4.2 — ST22 Security Token Records
🔗 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
🏦 Custody Agreements | Permanent | Empire Stock Transfer agreements |
📄 Series M Share Certificates | Permanent | Underlying equity documentation |
📊 Token Minting Records | Permanent | Issuance documentation |
🔗 Transfer Hook Configurations | Permanent | Security control settings |
📋 Reserve Oracle Data | 7 years | Daily balance verifications |
👤 Token Holder Registry | Permanent | Off-chain holder information |
📊 Transaction Logs | 7 years | Off-chain transaction records |
Section 4.3 — OTCM Utility Token Records
🔗 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📜 Token Sale Documents | Permanent | ICO/offering materials |
✅ SAFT/Purchase Agreements | Permanent | Token purchase agreements |
📊 Token Distribution Records | Permanent | All distributions |
🔒 Vesting Schedules | 7 years after full vesting | Locked token records |
💰 Staking Records | 7 years | Staking activity logs |
Section 4.4 — Wallet and Key Management
🔐 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
💳 Company Wallet Addresses | Permanent | All controlled wallets |
🔑 Key Generation Records | Permanent | Key ceremony documentation |
👥 Multi-Sig Configurations | Permanent | Signer requirements |
📋 Wallet Access Logs | 7 years | Access and transaction logs |
🔄 Key Rotation Records | 7 years | Key changes and reasons |
Section 4.5 — Platform Operations
🔗 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📋 Issuer Onboarding Records | Permanent | All issuer documentation |
📊 Trading Volume Data | 7 years | Historical platform data |
💧 Liquidity Pool Records | 7 years | Pool configurations, balances |
📈 Bonding Curve Parameters | Permanent | Historical configurations |
🔧 Platform Incident Reports | 7 years | Security incidents, outages |
📊 API Access Logs | 3 years | Third-party integrations |
Section 4.6 — Transfer Agent Records
Per SEC Rules 17Ad-6 and 17Ad-7:
📋 Record Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📊 Master Securityholder File | Permanent | DLT-based records |
🔄 Transfer Journals | 6 years | All transfers |
❌ Cancelled Certificates | 6 years | Physical and digital |
📋 Stop Transfer Orders | 6 years | Stop orders and releases |
📝 Written Communications | 6 years | Holder correspondence |
📊 Reconciliation Records | 6 years | Daily reconciliations |
💻 ARTICLE V: ELECTRONIC RECORDS MANAGEMENT
Section 5.1 — Email Retention
📧 Email Category | 📅 Retention Period | 📋 Notes |
|---|---|---|
💼 Business Critical | Per subject matter schedule | Contracts, legal, financial |
📋 Operational | 3 years | Day-to-day business |
🗑️ Transitory | 1 year | Scheduling, routine inquiries |
⚠️ Litigation Hold | Until hold released | All related emails |
📧 Email Best Practices:
✅ Practice | Description |
|---|---|
📁 Filing | File business-critical emails to appropriate folders |
🏷️ Categorization | Use consistent subject lines and categories |
🔗 Attachments | Save important attachments separately |
🚫 Personal | Do not use company email for personal matters |
Section 5.2 — Instant Messaging and Collaboration Tools
💬 Platform | 📅 Retention Period | 📋 Notes |
|---|---|---|
💼 Slack/Teams (Business) | 3 years | Business channels |
📊 Project Channels | Life of project + 3 years | Project-specific |
🔒 Confidential Channels | 7 years | Legal, HR, Finance |
📱 Text Messages (Business) | 3 years | Business-related SMS |
Section 5.3 — Cloud Storage and SaaS
☁️ System | 📅 Retention Period | 📋 Notes |
|---|---|---|
📁 Google Drive/OneDrive | Per document type | Apply document schedules |
📊 CRM Data | 7 years after relationship ends | Customer/issuer records |
💰 Accounting Software | 7 years | Financial data |
👤 HR Systems | Per employment record schedule | Personnel data |
🔧 Development Tools | Life of product + 5 years | Code repositories, tickets |
Section 5.4 — Database Records
💾 Database Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
👤 User Account Data | 7 years after account closure | Platform user records |
📊 Transaction History | 7 years | All platform transactions |
📈 Analytics Data | 5 years | Aggregated platform data |
📋 Audit Logs | 7 years | System access logs |
🔐 Security Logs | 7 years | Authentication, authorization |
Section 5.5 — Backup and Disaster Recovery
💾 Backup Type | 📅 Retention Period | 📋 Notes |
|---|---|---|
📅 Daily Backups | 30 days | Rolling daily |
📆 Weekly Backups | 12 weeks | Rolling weekly |
📊 Monthly Backups | 24 months | Rolling monthly |
📁 Annual Backups | 7 years | Year-end snapshots |
🔗 Blockchain Node Data | Permanent | Full node archives |
⚖️ ARTICLE VI: LITIGATION HOLD PROCEDURES
Section 6.1 — Triggering Events
A Litigation Hold must be implemented when any of the following occurs:
🚨 Trigger Event | Action Required |
|---|---|
⚖️ Lawsuit Filed | Immediate hold on all related records |
📋 Demand Letter Received | Immediate hold pending evaluation |
🔍 Government Investigation | Immediate hold on all related records |
⚠️ Anticipated Litigation | Hold when litigation reasonably anticipated |
📊 Regulatory Inquiry | Hold on all requested categories |
🔒 Internal Investigation | Hold as directed by Legal |
Section 6.2 — Litigation Hold Process
⚡ Step | Action | Responsible Party |
|---|---|---|
1️⃣ | Identify triggering event | Legal Department |
2️⃣ | Define scope of hold | Legal Department |
3️⃣ | Identify custodians and systems | Legal + IT |
4️⃣ | Issue written hold notice | Legal Department |
5️⃣ | Suspend destruction of affected records | All Custodians |
6️⃣ | Collect and preserve relevant records | IT + Custodians |
7️⃣ | Document preservation efforts | Legal Department |
8️⃣ | Monitor compliance with hold | Legal Department |
9️⃣ | Release hold when appropriate | Legal Department |
Section 6.3 — Litigation Hold Notice
All Litigation Hold notices must include:
📋 Element | Description |
|---|---|
📅 Date | Date hold is effective |
📋 Matter | General description of matter (if appropriate) |
📁 Scope | Categories of records subject to hold |
⏱️ Time Period | Relevant date range |
🚫 Prohibition | Clear prohibition on destruction |
👤 Contact | Person to contact with questions |
✅ Acknowledgment | Requirement to acknowledge receipt |
Section 6.4 — Blockchain Records and Litigation Holds
🔗 Record Type | Hold Procedure |
|---|---|
📊 On-Chain Data | No action needed (immutable) |
📋 Off-Chain Metadata | Standard hold procedures apply |
💳 Wallet Access Logs | Preserve all access records |
🔧 Smart Contract Modifications | Document and preserve |
📊 Platform Analytics | Export and preserve relevant data |
Section 6.5 — Consequences of Non-Compliance
🚨 Consequence | Description |
|---|---|
⚖️ Spoliation Sanctions | Court-imposed penalties for destruction |
📊 Adverse Inference | Jury may assume destroyed evidence was harmful |
💰 Monetary Sanctions | Fines and cost-shifting |
👤 Personal Liability | Individual responsibility for destruction |
🚪 Termination | Employment termination for intentional destruction |
🗑️ ARTICLE VII: DOCUMENT DESTRUCTION
Section 7.1 — Destruction Authorization
Records may only be destroyed when:
✅ Condition | Requirement |
|---|---|
📅 Retention Period Expired | Minimum retention period has passed |
⚖️ No Litigation Hold | No active or anticipated hold |
🔍 No Audit | No pending audit requiring records |
✅ Approval Obtained | Required approvals received |
📋 Documented | Destruction properly documented |
Section 7.2 — Destruction Methods
📁 Record Type | 🗑️ Destruction Method |
|---|---|
📄 Paper Documents (Confidential) | Cross-cut shredding or incineration |
📄 Paper Documents (Non-Confidential) | Recycling acceptable |
💾 Electronic Media | Secure wiping (DoD 5220.22-M or equivalent) |
💿 Hard Drives/SSDs | Degaussing and physical destruction |
☁️ Cloud Data | Certified deletion with confirmation |
🔗 Blockchain Data | Cannot be destroyed (document off-chain only) |
Section 7.3 — Destruction Documentation
All destruction must be documented with:
📋 Field | Description |
|---|---|
📅 Date | Date of destruction |
📁 Records Destroyed | Description of records |
📆 Date Range | Dates covered by records |
🗑️ Method | Destruction method used |
👤 Authorized By | Person authorizing destruction |
👤 Performed By | Person/vendor performing destruction |
📄 Certificate | Certificate of destruction (if vendor) |
Section 7.4 — Annual Destruction Cycle
📅 Month | Activity |
|---|---|
January | Identify records eligible for destruction |
February | Verify no litigation holds or audits |
March | Obtain required approvals |
April | Execute destruction |
May | Document and file certificates |
Section 7.5 — Destruction Prohibitions
🚫 NEVER destroy records:
- Subject to a Litigation Hold
- Requested by regulators or auditors
- Before retention period has expired
- Without proper authorization
- That may be relevant to anticipated litigation
👥 ARTICLE VIII: RESPONSIBILITIES
Section 8.1 — Board of Directors
📋 Responsibility | Description |
|---|---|
✅ Approval | Approve this Policy and material amendments |
👁️ Oversight | Oversee compliance with retention requirements |
📊 Review | Review annual compliance report |
Section 8.2 — Chief Executive Officer
📋 Responsibility | Description |
|---|---|
🎯 Tone at Top | Set expectations for compliance |
💰 Resources | Allocate resources for implementation |
📋 Accountability | Hold departments accountable |
Section 8.3 — Chief Legal Officer / General Counsel
📋 Responsibility | Description |
|---|---|
⚖️ Litigation Holds | Implement and manage litigation holds |
📋 Legal Guidance | Advise on retention requirements |
🔍 Compliance | Monitor compliance with legal requirements |
📊 Updates | Recommend Policy updates |
Section 8.4 — Chief Financial Officer
📋 Responsibility | Description |
|---|---|
💰 Financial Records | Ensure retention of financial records |
🔍 Audit Support | Support audit record requirements |
📊 Tax Records | Ensure retention of tax records |
Section 8.5 — Chief Technology Officer
📋 Responsibility | Description |
|---|---|
🔗 Blockchain Records | Oversee blockchain record retention |
💾 Systems | Implement technical retention controls |
🔐 Security | Ensure secure storage and destruction |
💾 Backups | Manage backup retention schedules |
Section 8.6 — Compliance Officer
📋 Responsibility | Description |
|---|---|
📋 Administration | Day-to-day Policy administration |
🎓 Training | Conduct retention training |
🔍 Monitoring | Monitor compliance |
📊 Reporting | Prepare compliance reports |
Section 8.7 — Department Heads (Record Custodians)
📋 Responsibility | Description |
|---|---|
📁 Department Records | Ensure proper retention of department records |
👥 Staff Training | Train staff on retention requirements |
🗑️ Destruction | Authorize department record destruction |
⚖️ Litigation Holds | Implement holds within department |
Section 8.8 — All Employees
📋 Responsibility | Description |
|---|---|
📁 Compliance | Comply with this Policy |
🎓 Training | Complete required training |
⚖️ Holds | Comply with litigation holds |
🚨 Reporting | Report potential violations |
⚠️ ARTICLE IX: COMPLIANCE AND ENFORCEMENT
Section 9.1 — Training
🎓 Training Type | Frequency | Audience |
|---|---|---|
📋 Initial Training | Upon hire | All employees |
🔄 Annual Refresher | Annually | All employees |
🔗 Blockchain-Specific | Upon assignment | Technical staff |
⚖️ Litigation Hold | As needed | Affected custodians |
👔 Management Training | Annually | Department heads |
Section 9.2 — Auditing
🔍 Audit Type | Frequency | Scope |
|---|---|---|
📋 Compliance Audit | Annually | Policy compliance |
💾 Systems Audit | Annually | Technical controls |
🔗 Blockchain Audit | Quarterly | On-chain/off-chain alignment |
🗑️ Destruction Audit | Annually | Destruction practices |
Section 9.3 — Violations
Violations of this Policy may result in:
🚨 Consequence | Description |
|---|---|
⚠️ Verbal Warning | Minor or first-time violations |
📝 Written Warning | Repeated or more serious violations |
🚪 Termination | Intentional destruction or serious violations |
⚖️ Legal Liability | Personal liability for spoliation |
💰 Regulatory Penalties | Fines for regulatory non-compliance |
Section 9.4 — Reporting Violations
📋 Reporting Channel | Contact |
|---|---|
📧 Compliance Officer | compliance@otcmprotocol.com |
📞 Ethics Hotline | [To be established] |
👔 Direct Supervisor | Department management |
⚖️ Legal Department | legal@otcmprotocol.com |
🛡️ No Retaliation: The Company prohibits retaliation against anyone who reports a good faith concern about Policy compliance.
🏛️ ARTICLE X: ADMINISTRATION
Section 10.1 — Policy Owner
The Chief Legal Officer is the owner of this Policy and is responsible for:
📋 Duty | Description |
|---|---|
📊 Maintenance | Keeping Policy current |
🔍 Interpretation | Providing authoritative interpretation |
📋 Amendments | Recommending amendments |
📊 Reporting | Reporting to Board on compliance |
Section 10.2 — Annual Review
This Policy shall be reviewed annually by the Legal Department and updated as necessary to reflect:
🔄 Review Area | Consideration |
|---|---|
⚖️ Legal Changes | New laws and regulations |
🔗 Technology Changes | New systems and platforms |
💼 Business Changes | New business activities |
📊 Audit Findings | Issues identified in audits |
🏆 Best Practices | Industry developments |
Section 10.3 — Amendment Procedures
💰 Amendment Type | Approval Required |
|---|---|
📋 Administrative | Chief Legal Officer |
📅 Retention Schedule Changes | CEO + CLO |
🏛️ Material Policy Changes | Board of Directors |
Section 10.4 — Questions
📧 Contact: compliance@otcmprotocol.com
Questions regarding this Policy or specific retention requirements should be directed to the Compliance Officer or Legal Department.
✍️ ACKNOWLEDGMENT AND CERTIFICATION
I acknowledge that I have received and read the OTCM Protocol, Inc. Document Retention Policy. I understand its contents and agree to comply with all of its terms and conditions.
I understand that I am responsible for retaining records in accordance with this Policy and the applicable retention schedules.
I agree to comply with any Litigation Hold notices I receive and understand that failure to preserve records subject to a hold may result in serious consequences for the Company and for me personally.
I understand that intentional destruction of records in violation of this Policy or a Litigation Hold may result in disciplinary action, up to and including termination, and may expose me to personal legal liability.
Field | Value |
|---|---|
Signature | _________________________________ |
Date | _________________________________ |
Printed Name | _________________________________ |
Title/Position | _________________________________ |
Department | _________________________________ |
📎 APPENDIX A: QUICK REFERENCE RETENTION SCHEDULE
🏢 Corporate
Record | Retention |
|---|---|
Articles/Bylaws | Permanent |
Board Minutes | Permanent |
Stock Records | Permanent |
Annual Reports | Permanent |
💰 Financial
Record | Retention |
|---|---|
Financial Statements | Permanent |
General Ledger | Permanent |
AP/AR Records | 7 years |
Bank Statements | 7 years |
📋 Tax
Record | Retention |
|---|---|
Tax Returns | Permanent |
Supporting Docs | 7 years |
👤 Employment
Record | Retention |
|---|---|
Personnel Files | 7 years after termination |
Payroll | 7 years |
I-9 Forms | 3 years or 1 year after term |
⚖️ Legal
Record | Retention |
|---|---|
Contracts | 10 years after expiration |
Litigation Files | 10 years after resolution |
IP Records | Permanent |
🔗 Blockchain
Record | Retention |
|---|---|
Smart Contracts | Permanent |
Custody Agreements | Permanent |
Token Records | Permanent |
Transaction Logs | 7 years |
OTCM Protocol, Inc. A Wyoming Digital Asset Corporation
📜 SEC Category 1 Issuer-Sponsored Tokenized Securities Infrastructure
Document ID: OTCM-POL-DRP-001 | Version 1.0 | Effective: January 30, 2026