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June 18, 2020 at 04:23 PM
A recent action taken by the Financial Industry Regulatory Authority against a chief compliance officer shows the importance of reviewing and retaining business-related electronic communications.
The broker-dealer self-regulator recently took action against a CCO failing to retain business emails and using an outside email to conduct business.
In a Smarsh blog, Eversheds Sutherland attorneys Brian Rubin and Amanda Oliveira note that FINRA has shown that it places great emphasis on the review and retention of business-related electronic communication — bringing enforcement actions against reps, compliance officers and firms.
The CCO, Jamie Bennett, who was responsible for the firm’s supervision, retention and review of emails, as well as maintenance of the firm’s books and records, failed to take any steps to review or retain on behalf of the firm representatives’ emails.
Specifically, Bennett ”failed to ensure that the firm captured, reviewed, or retained emails sent and received by one representative, as well as certain business-related emails sent and received by the CCO himself through his outside email address,” Rubin and Oliveira write.
