Sixteen Wall Street firms have reached resolutions with the SEC in cases relating to widespread failures to maintain and preserve electronic communications. The focus of the investigations was “pervasive off-channel communications,” on employees’ personal devices that the firms failed to retain and preserve, as required by federal securities laws. The firms agreed to pay combined penalties of $1.1 billion, with individual penalties ranging from $10 million for Cantor Fitzgerald up to $125 million for firms including Barclays, Citigroup, Credit Suisse, Deutsche, and Morgan Stanley. The firms also agreed to retain compliance consultants to conduct comprehensive reviews of their policies and procedures relating to the retention of electronic communications on personal devices and their frameworks for addressing non-compliance by their employees. In a parallel effort, the CFTC announced a combined $710‑million resolution with 11 firms over similar violations. The sweeping industry probe is one of the largest collective resolutions for the SEC and CFTC. See “JPMorgan Fined $200 Million for Failure to Maintain Electronic Communication Records” (Mar. 2, 2022) and “Retaining Business Records in an Era of Disappearing Messaging Apps” (Nov. 14, 2018).