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IAA 1940 Rule 204-2(a)(7)
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SEC still live and kicking as 12 firms fined combined $63m+ in recordkeeping failure charges
Each firm used unapproved communication methods, or off-channel communications, to send and receive messages that were required to be maintained under the securities laws, the SEC said.
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Atom Investors dinged for ecomms recordkeeping lapses, but no fine imposed
The firm received no penalty because of its proactive approach, swift remediation and substantial cooperation efforts with the SEC’s investigation of a third party.