Beyond the SEC Fines: Off-Channel Communications and Your Compliance Roadmap


The financial services industry has been on edge since the fall of 2022, when the Securities and Exchange Commission (SEC) announced the results of a sweeping examination and enforcement effort targeting broker-dealers' use of off-channel communications. The resulting penalties exceeded US$1.1 billion, sending shockwaves throughout the industry. Reports emerged that the SEC's enforcement efforts then expanded to the buyside, with several large fund managers rumored to be under review for their communication surveillance practices. Speculation grew as to whether registered investment advisers (RIAs) would face similar scrutiny, measured against broker-dealers' standards and record-keeping requirements.

While details remain sparse, it's clear that the SEC's approach to buyside firms has been nuanced, with key distinctions that warrant close attention. In an era of rapidly evolving technology and the potential for human error, compliance with regulatory requirements is both crucial and challenging. The sweep now has been expanded to RIAs, so understanding the facts and taking proactive steps to enhance compliance can help firms prepare for potential regulatory inquiries and mitigate risk.

Join us on April 6 for a conversation with William V. de Cordova of Akin, where we will discuss the SEC's recent enforcement actions, the scope of the current expanded sweep, and how your firm can strengthen its practices, policies, and procedures to address regulatory concerns. Audience questions are welcome and encouraged.

We look forward to your participation in this timely and informative session. To register, please click the link below.


William V. de Cordova, Senior Regulatory Counsel, Akin Gump Strauss Hauer & Feld LLP

Suzan Rose, Senior Advisor, Government & Regulatory Affairs, AIMA


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