Enforcement Alert: Retain even your contract reps' business-related e-mail - or risk fines

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Make sure you have ready access to the e-mail communications that reps are using to conduct business for your firm – even if those reps aren’t your immediate employees. That’s the takeaway from a recent FINRA enforcement action.

Regardless of whether the rep is independent, the reps should be required to use your e-mail system, says Amy Lynch, president of FrontLine Compliance LLC, a regulatory compliance consulting firm based in Leesburg, Va. and New York. At the very least, don’t allow them to use outside accounts unless they can be immediately captured by your e-mail system, she adds.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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