Books and Records

The Commission staff’s investigation found off-channel communications by Apollo personnel, including at senior levels. These communications were sent among colleagues as well as to external ...

Beginning in 2024, the Carlyle Group and its investment adviser affiliates began to roll out on-channel messaging platforms for external communications

Schwab provided its personnel with firm-issued devices or other firm-approved applications, making communications through approved channels more readily available, and disciplined personnel who violated its ...

An unauthorized third party fraudulently persuaded a Robinhood employee to download remote access software onto a Robinhood computer and give the actor control of the ...

These off-channel communications included records required to be preserved under the Advisers Act because they related to a recommendation made or proposed to be made ...

The adviser failed to implement sufficient monitoring to ensure that its recordkeeping and communications policies were being followed

The compliance department did not collect the referenced WhatsApp messages from the partner

A failure to preserve 14,000 records led to a $30,000 FINRA fine

"We consider a firm’s efforts to comply with its recordkeeping obligations and to prevent off-channel communications, focusing, for example, on timely adoption of meaningful technological ...

The firm was further dinged for improperly permitting one of its FAs to engage in securities activities with and for persons in the U.S., when ...