Since February 2022, the SEC has brought more than two dozen enforcement proceedings against broker-dealers, as well as certain affiliated investment advisers, for failing to preserve business communications made on personal devices and/or through unapproved messaging platforms (collectively, off-channel communications) in accordance with SEC rules. It was only a matter of time before the SEC set its sights on registered advisers. In what appears to be the first standalone action against an investment adviser for such violations, the SEC penalized an adviser for failing to preserve off-channel communications and other alleged compliance failures. In addition to paying a $6.5‑million civil penalty, the firm will, as in other similar proceedings, retain a compliance consultant to review its policies, procedures and practices for monitoring for and preserving off-channel communications. This article parses the alleged violations and the terms of the settlement, with commentary from Igor Rozenblit, managing partner at Iron Road Partners, who previously held several senior positions at the SEC, including Co-head of the Private Funds Unit of the Division of Examinations. See “16 Firms Fined $81 Million in Latest SEC Electronic Communications Recordkeeping Settlements” (Apr. 11, 2024); and “SEC and CFTC Continue to Penalize Firms for Electronic Communications Recordkeeping Violations” (Aug. 17, 2023).