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The SEC and FINRA have recently issued billions in fines for “off‑channel” communications.
The numbers are staggering, and compliance officers can no longer treat this as a theoretical risk. Since launching its enforcement sweep in late 2021, the SEC has charged over 100 firms and collected more than $2 billion in penalties. The number increases to over $3.5 billion when you add FINRA and other regulator fines.
In 2025 alone, the SEC slapped roughly $63 million in fines on a cohort of investment advisers and broker‑dealers for off‑channel recordkeeping breaches.
The most common violation is almost always the same—failure to retain business communications sent outside firm‑approved systems.
For financial advisory firms, that regulatory pressure means internal compliance teams must urgently tighten mobile communication controls.
The checklist below will help you align your firm’s policies and systems with SEC and FINRA expectations.
As a result, you can protect your business from fines, operational disruption, and reputational damage.
Let’s dive in.
Table of Contents
1. Capture and archiving (the "what”)
2. Regulatory specifics (the “how”)
3. Operational integrity (the “who”)
5. Action plan for compliance officers
6. Next steps—secure your firm’s mobile compliance with iPlum
1. Capture and archiving (the "what”)
Your firm’s ability to capture and preserve mobile communications is the foundation of compliance.
You see, regulators are looking for more than intent. They want to see concrete systems that prevent data loss and tampering.
In practice, this means firms must go beyond capturing basic text messages.
To satisfy SEC and FINRA examiners, your archiving solution must cover all communication channels, store them immutably, and preserve critical context like sender identity and timestamps.
Here’s what that entails:
All-channel capture
Most firms capture SMS messages. However, that’s only part of the picture.
Advisors often use MMS to send images, documents, or audio clips, all of which fall under SEC and FINRA recordkeeping rules.
Voice calls, especially those made on mobile devices, must also be recorded and archived when used for client communication.
Your compliance program, therefore, must ensure that you capture every format, including text, images, files, and calls, across all devices and operating systems.
Immutable storage (WORM)
SEC Rule 17a-4(f) requires that firms store electronic records in a non-rewriteable, non-erasable format, commonly referred to as WORM (Write Once, Read Many).
This prevents anyone, including advisors or IT administrators, from altering or deleting archived records. Without immutable storage, your data could be disqualified during an audit or enforcement action.
Think of WORM compliance as a technical safeguard that proves your records haven’t been tampered with, intentionally or otherwise.
Metadata preservation
Preserving the content of a message isn’t enough.
Regulators expect to see metadata that establishes the full context of a communication. This includes timestamps, sender and recipient identities, message type, and delivery status. Proper metadata makes messages searchable, sortable, and auditable, all of which are essential during an exam or internal investigation.
Without metadata preservation, your firm could appear disorganized or evasive, even if the messages themselves are benign.
Automated recording
Manual communication systems, where the advisor must remember to start or save a recording, introduce a serious compliance risk. And, in recent enforcement actions, regulators have cited manual capture systems as a red flag.
That said, you can leverage automated recording to remove human error by capturing all messages and calls in real time.
2. Regulatory specifics (the “how”)
Capturing data is only half the battle. Your systems must also meet specific retention, access, and disclosure requirements laid out by the SEC and FINRA.
These rules are detailed mandates with measurable expectations.
Below are the four technical and procedural capabilities your mobile archiving system must support to pass regulatory scrutiny.
SEC Rule 17a-4 compliance
SEC Rule 17a-4 requires firms to retain electronic records in a tamperproof format for three or six years, depending on the record type. These records must remain instantly accessible for the first two years and retrievable promptly thereafter.
If your system fails to retain messages in a secure, non-rewriteable format, you are already out of compliance.
Therefore, be sure to use WORM storage and automate retention timelines to align with the SEC’s strict data preservation requirements.
FINRA Rule 4511
FINRA Rule 4511 requires that firms make books and records available promptly upon request.
Thus, your team must be able to locate, retrieve, and present archived mobile messages in an organized and auditable format. In addition, build your archive with FINRA examiner access in mind. Because simplicity, speed, and clarity are non-negotiable when it’s time to produce records.
Search and discovery
During an exam or internal investigation, your compliance officer must be able to search across all records instantly. This includes filtering messages by keyword, date, sender, or specific representative.
A search function that’s slow, limited, or siloed by device makes your entire archive less defensible. Robust search and discovery functionality, on the other hand, transforms a data lake into an organized, usable compliance asset.
And, this helps your team respond to regulator questions with speed and accuracy.
Disclosures
Many states follow two-party consent laws, which means both parties must know that a call is being recorded.
If your phone system doesn’t provide an automated announcement, such as “This call is being recorded”, you could violate both state law and firm policy in one move. Use technology that embeds these disclosures by default.
Disclosures allow you to meet legal requirements. It also helps protect client trust by promoting transparency from the first interaction.
3. Operational integrity (the “who”)
Regulators want to know who controls what, how data access is restricted, and whether employees follow approved protocols.
And as your firms adopt mobile-first communication tools, operational integrity is critical.
You must, therefore, draw a line between personal and professional data, monitor usage from a central location, and enforce firm-wide standards.
Here are four practices that define whether your compliance program is truly enforceable.
BYOD separation
Some advisors use their personal phones for work. That’s fine, but only if business and personal data stay separate.
Without clear boundaries, client messages can mix with family group texts, photos, or app notifications. And that’s a problem during an audit. So, be sure to use a secure business line that keeps work communication in its own space.
BYOD separation ensures privacy and helps you retain control over records subject to SEC and FINRA rules.
Centralized oversight
Your Chief Compliance Officer must have a centralized dashboard that displays real-time data from all advisors, including message logs, call records, and compliance alerts.
You don’t want fragmented systems as they create blind spots that regulators interpret as weak supervision.
Centralized oversight allows your CCO to monitor firm-wide behavior, flag issues early, and demonstrate proactive governance during audits or examinations.
Employee attestation
A written policy doesn’t mean much unless employees agree to follow it.
Therefore, insist that every advisor signs an attestation stating they will only use the firm-approved, archived platform for business communication.
This formal step reinforces accountability, establishes clear expectations, and helps protect the firm in enforcement scenarios. In addition, keep signed attestations on file as part of your supervisory documentation. That way, if a violation occurs, you can show regulators that the advisor knowingly deviated from documented policy.
Termination procedures
When an advisor leaves your firm, you must cut off their access to client communications immediately, without losing historical records.
Therefore, use a communication system that allows for instant access revocation while preserving all archived data tied to that individual. Furthermore, termination procedures must be swift, repeatable, and auditable. Otherwise, you risk compliance gaps during transitions.
Besides, having a standardized offboarding protocol protects client information, ensures continuity, and satisfies examiners who want to see access controls in action.
4. Integration and security
You may have the best archiving system. However, it won’t help if it operates in a silo or leaves data exposed.
For true compliance, your mobile communication platform needs to work well with the tools your firm already uses and protect sensitive data.
With such a system, you can sync messages to your CRM, lock down access, and encrypt data behind the scenes.
Here’s what integration and securing include:
Data encryption
Regulators want you to protect client data, at rest and in transit. That’s where encryption comes in.
Your system must encrypt all data in transit and at rest. That way, it prevents unauthorized access and keeps sensitive messages safe from leaks or attacks. Encryption makes messages unreadable even if intercepted by unauthorized parties.
So, when you use strong encryption across the board, you show regulators that your firm takes data security seriously.
MFA access
Cyberattacks often start with stolen passwords. Therefore, multi-factor authentication (MFA) is a must.
Your admin console should always require at least two layers of verification, like a password plus a code sent to your phone.
MFA blocks unauthorized access, even if someone guesses a password. More importantly, it protects your data and your compliance reputation at the same time.
5. Action plan for compliance officers
Policies and tech platforms are crucial. However, proper execution is what keeps your firm out of trouble.
You, therefore, need a solid plan to close the gaps between what’s required and what’s actually happening. And that starts with knowing how advisors communicate today, putting the right tools in place, and checking regularly to ensure everything stays on track.
Be sure to use the following three steps to build a compliance process that works and holds up during an audit.
Audit
Start by figuring out who’s texting clients through unapproved channels.
Look for native apps like iMessage, WhatsApp, or even basic SMS. These messages may not be getting captured, and that’s a big problem. While at it, talk with your advisors, run a tech audit, and ask your IT team for usage logs.
While this step may feel uncomfortable, it’s essential because you can’t fix what you don’t see. Once you know the scope of the issue, you can move quickly to contain it.
Standardize
Next, roll out a firm-wide solution that solves the problem for good.
Choose a platform like iPlum to create a clear boundary between personal and business communication. iPlum allows you to archive data automatically and work across devices.
In addition, don’t allow advisors to “choose their own” workaround. Standardization makes training easier and gives you complete visibility. It also underscores your firm’s commitment to communication compliance.
Remember, the simpler the system, the more likely your team will adopt and use it.
Review
Even with the right tech in place, you need to check that it’s working.
Therefore, set a quarterly review schedule to sample archived texts and calls across the firm. Look for tone, content, and compliance with firm policies. If something feels off, address it early. This step allows you to catch mistakes and build a record of oversight.
After all, regulators want proof that your firm is storing messages and actively reviewing them.
Next steps—secure your firm’s mobile compliance with iPlum
Compliance with SEC and FINRA mobile communication rules doesn’t have to feel overwhelming.
When you break it down, it comes down to five key areas:
- Capturing the right data
- Following the right rules
- Enforcing the right behavior
- Securing your systems
- Proper implementation and regular reviews
If your firm can do those five things, you’ll avoid fines, and you’ll build trust with clients, regulators, as well as your own team.
The easiest way to get started?
Sign up for iPlum.
The platform gives your advisors a separate, secure business line with automatic archiving, built-in compliance features, and total control for your compliance team.
Click here to get started with iPlum’s compliance solution for financial professionals
