The Investment Investment Group (IPG) agreed to pay a fine of $ 100,000 as part of a settlement with the Financial Industry Regulatory Authority (FINRA).
Starting in January 2020, IPG allowed employees to use an electronic messaging platform provided by suppliers for business purposes.
However, from January 2020 and November 2022, IPG has failed to establish, maintain and impose a supervisory system, including written supervisory procedures (WSPS), which is reasonably designed to achieve compliance with the obligation of the business to maintain and review the communications that are related to the business. taken through the approved messaging platform.
In January 2020, the company participated in a third supplier to arrest the messages they sent and received by its employees so that the company could maintain and review them. In order for the archive service to capture messages sent and obtained by an employee through the messaging platform, the employee’s personal device had to be connected to the archiving service.
However, the company did not take reasonable measures to verify that its employees’ devices were actually connected and remained connected to the archive service and that the messages of the workers sent and received through the messaging platform were actually recorded by the Archive Service.
In addition, the company’s WSPs did not deal with the use of the messages platform or describe how the business managers should verify that employees’ devices were connected and remained connected to the archive service.
During the relevant period, IPG employees who were authorized to use the messages platform were either never connected to the archive service or were connected only for part of the time. Therefore, an unknown number of messages related to employee businesses were never maintained or revised by the business.
In addition, the company was unable to produce all the messages that responded to a Finra request in relation to the revision of a customer complaint.
As a result, IPG violated the Law on Exchange § 17 (A), the Law on Article 17A-4 and the FINRA 4511, 3110 and 2010 rules.
In addition to the $ 100,000 fine, the company agreed to a accusation and a business that a member of its senior administration, who is a registered manager of the business, must certify in writing that the company has restored issues and applied a supervisory system, including WSPS, reasonably designed to achieve its Law. (a)