For three years the SEC’s off-channel communications sweep was a broker-dealer story — nine-figure settlements at the wirehouses, more than $2 billion in penalties across the broader sweep, and compliance officers everywhere quietly checking their own text messages. Then the sweep reached investment advisers, including standalone RIAs with no broker-dealer affiliation: the August 2024 round alone covered twenty-six firms and $392.75 million in combined penalties, and a January 2025 round added twelve firms and $63 million — both rounds included registered investment advisers. The theory of the case travels: if business communications happened on personal devices and weren’t retained, the books-and-records obligation was violated — no breach, no client harm, no fraud required.
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