Books and Records

The federal securities laws impose recordkeeping requirements on broker-dealers to ensure that they responsibly discharge their crucial role in our markets. The Commission has long ...

The firm failed to maintain and preserve off-channel communications its employees sent and received related to the broker-dealer’s business, CGMI received and responded to Commission ...

In September 2021, the Commission staff commenced a risk-based initiative to investigate whether broker-dealers were properly retaining business-related messages sent and received on personal devices. ...

Goldman Sachs’s widespread failure to implement its policies and procedures that prohibit such communications led to its failure to reasonably supervise its employees

Jefferies’ supervisors, who were responsible for preventing this misconduct among junior employees, routinely communicated off-channel using their personal devices

An associate on a derivatives trading desk exchanged more than 2,500 messages with Morgan Stanley colleagues, including several managing directors. The associate also texted with ...

As a result, UBS’s recordkeeping failures likely impacted the Commission’s ability to carry out its regulatory functions and investigate violations of the federal securities laws ...

While permitting employees to use approved communications methods, including on personal phones, for business communications, NSI failed to implement sufficient monitoring to assure that its ...

Credit Suisse’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 ...

These proceedings arise out of the widespread and longstanding failures of employees throughout the firms, including at senior levels, to adhere to certain of these ...