3b. ALL - Supervision & Compliance of Off-Channel Communications (Intermediate - OPEN)

Monday
Written By Holly Orefice

Off-channel communications are any internal or external communications which are not being monitored or retained by your firm.  Common examples include text messages from personal cell phones, messaging apps such as WhatsApp and social media messages.  Most firms have policies prohibiting off-channel communications, yet this remains an industry-wide issue.  The regulators have had numerous enforcement actions for off-channel communications. This session will explore alternative paths to compliance and ways to help bridge this gap. 

This session is open to regulators but closed to members of the press.

Learning Objectives:

  • Reviewing recent regulatory guidance and enforcement actions.

  • Discussing policies prohibiting off-channel communications: effectiveness, training, attestations and testing; in addition to obligations regarding record retention requirements.

  • Discussing technological solutions, including the advantages/disadvantages and capturing off-channel communications.

  • Navigating the privacy considerations for reviewing personal cell phones and electronic devices to verify no use of off-channel communication.

Featured
Trish Flynn
Trish Flynn

VP & Chief Compliance Officer

PGIM Investments

Patrick Hayes
Patrick Hayes

Chair, Investment Management

Calfee Halter & Griswold LLP

Rob Saperstein
Rob Saperstein

Head of Compliance

Guggenheim Investments

EXCLUSIVELY SPONSORED BY

Holly Orefice
Previous

3a. ALL – Ethical Practice Programs in Action (Intermediate - OPEN)
Next

3c. ALL LAB – MNPI: Preventing Illegal “Insider Trading” (Intermediate - CLOSED)