The SEC’s Intensified Scrutiny of Off-Channel Communications at Registered Firms

The U.S. Securities and Exchange Commission has maintained its focus to monitor and regulate off-channel communications of its registrants as highlighted in recent settlement actions in which the agency charged 11 Wall Street firms with widespread recordkeeping failures.

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About the Author: Walé Y. Oriola

Walé Oriola is counsel in Faegre Drinker’s investment management practice group. His practice is concentrated on advising investment advisers, investment companies, institutional investors and other financial services firms on federal and state securities laws and regulations. Walé draws on his U.S. Securities and Exchange Commission (SEC) experience to provide practical guidance on regulatory policy, including rulemaking proposals and implementations, transactional matters, including on the formation, offering and operation of investment products, compliance programs, disclosure, investment adviser formation, fiduciary counsel, examinations and enforcement investigations, and environmental, social and governance (ESG) matters.