Northwestern firms fined $16m for off-channel communications

During the time period that NMIS failed to maintain and preserve off-channel communications that its personnel sent and received related to NMIS’s broker-dealer business, NMIS received and responded to Commission subpoenas for documents and/or records requests in several Commission investigations. As a result, NMIS’s recordkeeping failures likely impacted the Commission’s ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations.