Originals of all written communications received and copies of all written communications sent by such investment adviser relating to:
(i) Any recommendation made or proposed to be made and any advice given or proposed to be given;
(ii) Any receipt, disbursement or delivery of funds or securities;
(iii) The placing or execution of any order to purchase or sell any security;
(iv) The performance or rate of return of any or all managed accounts or securities recommendations
Investment Advisers must retain e-communications, including collaboration chat, screen shares, and whiteboarding data, for five years.
Pursuant to Investment Advisers Act Rule 204-2, registered investment advisers must retain copies of any recommendation made or proposed to be made and any advice given or proposed to be given; any receipt, disbursement or delivery of funds or securities; order execution; or the performance or rate of return of any managed accounts or securities recommendations. These mandates extend to one-to-one and one-to-many chat capabilities included in collaboration platforms.
Theta Lake helps investment advisers comply with this Rule by capturing and archiving these communications, including dynamic content like gifs, emojis, links, and shared files. Once captured, Theta Lake leverages it AI-based risk and compliance detections to identify issues in the chat content, including the analysis of URLs, files, and images for potential regulatory, privacy, and cybersecurity risks.
