ThinkAdvisor published an article on June 18, 2020 discussing the importance surrounding broker-dealers retention and review of electronic communications. FINRA took action against a firm’s Chief Compliance Officer (“CCO”) for failing to retain business communications and for using an outside email address to conduct business. It was found that the CCO, responsible for supervision and retention and review of emails, failed to take the necessary steps to ensure the proper books and records were kept related to registered representatives (“RR”) emails as well as his own business emails.

It was found that although the CCO was aware of a certain RR’s use of outside email addresses, the CCO did not take action to ensure that the emails were captured until June 2015. Any emails sent via the outside address prior to June 2015 could have been deleted, therefore making the Firm’s books and records inaccurate. It was also found that the CCO almost always used an outside email address to conduct firm business. The CCO was fined $5,000 and suspended for 30 days.

The article also states that FINRA has placed an emphasis on the importance of retaining and reviewing business communications and has recently brought enforcement actions against RRs, CCOs and firms.

For the full article, please click here.

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