SEC CHARGES 10 BROKER/DEALERS/INVESTMENT ADVISERS WITH FAILURE TO KEEP RECORDS OF "OFF-CHANNEL COMMUNICATIONS" WITH CLIENTS
NASAA makes Series 66 Test Specifications available for those planning to sit for the Series 66 Exam. These recently revised Test Specifications describe the subject matter of the 66 Exam in some detail. The Series 66 Test Specifications include Section IV (G) (5) (5.3) covering correspondence with clients and advertising, mentioning the use of social media, digital messaging, and internet communications, and implying the obligations of proper Record-Keeping. From time to time, the SEC issues press releases about penalties and charges brought against broker/dealers and advisers. Here is one that imposes penalties on 10 firms for inadequate Record-Keeping of electronic communications with clients, called "Off-Channel Communications." I include this SEC Release here because it demonstrates that a broker or adviser must treat the rules as having real life consequences, potentially bringing serious penalties and large fines for non-observance. Bob Eder in his Study for the