Books and Records

The 16 firms pointed to an SEC enforcement settlement in January over off-channel communications that they contended ended with better terms than theirs

The firm elected to buy business phones for all staff, which has been shown to be a smart move

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