The SEC has, for many years, used broker-dealer and associated persons’ failure to create and maintain books and records as a basis for the imposition of serious penalties.  In recent actions, it appears to be continuing—and upping the ante on—its enforcement in this area. Simply stated, it is increasingly imperative for broker-dealers and investment advisory … Continue reading “Ubiquitous Use of WhatsApp and Other Unrecorded Internal Communications Result in Substantial Penalties in Recent SEC, CFTC Actions”