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OCIE Pings Advisers on Electronic Messaging Best Practices
21 December 2018
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An OCIE risk alert on electronic communications is a timely reminder for advisers to evaluate their use of electronic messaging (including text messages from personal devices, personal social media, and other applications and platforms) and update their policies and procedures to reflect current practices and ensure compliance with the Advisers Act.
Investment advisers should (i) ensure that they are preserving all electronic communications (including communications that are not made through the corporate e-mail system, such as text messages from personal devices and messaging services and applications) as required by the Advisers Act and (ii) adopt and implement policies and procedures concerning permitted forms and uses of electronic communications, as tailored for the specific facts and circumstances of the investment adviser.
Kenneth J. Berman
Robert B. Kaplan
Julie M. Riewe
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