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Electronic Communications Investment Adviser Books & Records

Sheppard Mullin Richter & Hampton LLP

What Private Equity Firms Need to Know About the Ongoing SEC Investigation of “Off-Channel” Communications

Over the last several years, the Securities and Exchange Commission (“SEC”) has been laser-focused on the use of so-called “off-channel communications” in the financial services industry. On the theory that employees’ use of...more

Sheppard Mullin Richter & Hampton LLP

SEC Off-Channel Communications Sweep

Over the last several years, the Securities and Exchange Commission (the “SEC”) and the Commodities Futures Trading Commission (“CFTC”) have been laser-focused on the use of so called “off-channel communications” in the...more

Paul Hastings LLP

Ephemeral Messaging at the Office: Avoiding Pitfalls and Establishing Best Practices

Paul Hastings LLP on

Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more

Lowenstein Sandler LLP

Regulators Crack Down on the Use of Messaging Apps as Wall Street Banks and Investment Advisers Hit With $1.8 Billion in Fines

Lowenstein Sandler LLP on

On September 27, 2022, regulators from the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) handed out over $1.8 billion in fines to financial institutions in connection with...more

Dechert LLP

OCIE Publishes Risk Alert on the Use of Electronic Messaging by Investment Advisers and Employees

Dechert LLP on

The U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert on December 14, 2018 concerning the use of electronic messaging by registered...more

Akin Gump Strauss Hauer & Feld LLP

SEC OCIE Issues Guidance on Advisers’ Recordkeeping Requirements for Electronic Messaging Following its Sweep Examination

• On December 14, the SEC’s OCIE issued a Risk Alert summarizing the findings of its limited-scope examination initiative relating to electronic messaging. • Noting a “pervasive use” of electronic messaging by adviser...more

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