A firm can have the most sophisticated electronic communications monitoring system, but it will do little good if the firm fails to add new employees to that system promptly. That is apparently what happened to a broker-dealer that allegedly failed to monitor about 3.5 million emails related to nearly 700 email accounts over a nine-year period, according to FINRA’s letter of acceptance, waiver and consent (AWC) with the firm. Although the AWC concerns a broker-dealer, it offers an important reminder for investment advisers of the need to ensure that electronic communications surveillance systems are implemented correctly. This article discusses the AWC, with insights on how to avoid onboarding issues from Jaqueline Hummel, director at ACA Group, and Amy Lynch, founder and president of FrontLine Compliance LLC. See “Four Electronic Communication and Recordkeeping Traps for Hedge Fund Managers to Avoid” (Oct. 26, 2023).