10.12 Retention of Records and Instructions

sufficient information to identify the beneficial owner of each account for which a record of an order is retained,

for a period of not less than seven years from the creation of the record of the order, and for the first two years, such record and information shall be kept in a readily accessible location.

on which the order of the Access Person was executed,

during the period of not less than seven years from the date of the origination of the order, and for the first two years, such information shall be kept in a readily accessible location.