Carl Ayers
The Commission requested documents in an unrelated investigation that revealed the use of off-channel and unpreserved communications. As a result, Glazer’s recordkeeping failures likely impacted ...
The firm gathered and produced emails and text messages, including those at senior levels, that were sent or received by text message on personal phones ...
Fusion failed to retain emails sent from 2019 through mid-2021 for over 60% of its IARs, including client correspondence it was required to retain. It ...
Merrill personnel became aware that Harvest was not systematically adjusting the number of options contracts that Harvest purchased in numerous accounts with pre-2017 IMAs, but ...
Brighton did not disclose the incentives related to the Clearing Agreement to its advisory clients and prospective clients until June 2022 when it revised its ...
The firms provided certain personnel with firm-issued devices that included technology that enabled the capture, retention, and archiving of communications (including text messages) sent and ...
After discovering the off-channel communications, the firm voluntarily conducted an internal review ... and took remedial actions by making changes to its compliance program, including ...
"In FY 2023, Division staff conducted more than 3,100 examinations across our tens of thousands of registrants"
"The use of off-channel communications—text messages, smartphone chat applications like WhatsApp, and personal email outside firm-approved systems—is prevalent across the securities industry. We have an ...
"Unnecessary redaction of final award determinations in the name of whistleblower confidentiality limits public information about the awards, and that, in turn, insulates the awards ...