Books and Records

Heed the lessons of the SEC’s latest off-channel communications enforcement action against an adviser and you may well sidestep a similar fate

"As with the recordkeeping cases and, frankly, all our cases, we consider whether a firm self-reported and cooperated with our investigation"

One of the seven FAQs addresses IA recordkeeping requirements tied to T+1 transition

Senvest failed to implement procedures to monitor whether its employees were following the firm’s policies concerning work-related communications .... At least three senior Senvest officers ...

Violators included “supervisors and senior-level employees”—including some attached to compliance—who used platforms, such as WhatsApp and text messaging, contrary to firm P&Ps

The CFTC enters the regulatory fray over firms' use of off-channel communications for work

'You cannot get deals if you’re not texting and your competitors are,' FirmScribe CEO says from PFCFO New York Forum.

Broker-dealer was charged with failing to reasonably supervise the use of personal e-mails for business-related communications

In the new legal cases targeting advisers, the SEC cited their responsibilities under Advisers Act section 204 (reports by IAs) and the books and records ...

Commission staff uncovered Cambridge’s misconduct after commencing a risk-based initiative to investigate the use of off-channel and unpreserved communications at broker-dealers. Cambridge has initiated a ...