SEC's First Off-Channel Communications Settlement With a Non-Broker Dealer RIA

Last week the SEC announced the first off-channel communications settlement with a registered investment adviser (RIA) who was not otherwise affiliated with a broker-dealer. This settlement provides new insight into how the SEC views advisers recordkeeping obligations with implications for investment adviser compliance programs.

We'll be discussing the settlement and what it means for RIAs. We will also discuss best practice for Off-Channel communications, how RIAs may assess these practices in response to some of the positions the SEC seems to take in the settlement, and how RIAs should respond if the SEC comes calling.

We recently published a blog post on the settlement and will be producing a more detailed alert in the coming days.