No Texting: Ehlers’ Electronic Communication Policy
E-Quarterly Newsletter - October 2024by Pam Ziermann, Chief Compliance Officer
As a regulated entity under both the Securities and Exchange Commission (SEC) and Municipal Securities Rulemaking Board (MSRB), Ehlers is bound by specific rules relative to recordkeeping for all business-related written communications between our employees and client contacts. Over the course of the last two years, the SEC has increasingly scrutinized firms for the lack of recordkeeping for business-related text messages to/from employees’ personal mobile devices. In fact, the SEC has fined several firms for violating these recordkeeping provisions of the Securities Exchange Act of 1934, some reaching as high as $125 million.
At Ehlers, we take regulatory compliance very seriously. As such, we must ask that clients refrain from business-related texting to Ehlers’ employees. If you need to reach an advisor or other staff member, please contact them via telephone or e-mail. This will help ensure we are following all applicable recordkeeping rules appropriately.
We thank you for your cooperation with this important compliance issue. If you have any questions, please don’t hesitate to contact your Ehlers advisor or our Chief Compliance Officer at pziermann@ehlers-inc.com.
Required Disclosures: Please Read
Ehlers is the joint marketing name of the following affiliated businesses (collectively, the “Affiliates”): Ehlers & Associates, Inc. (“EA”), a municipal advisor registered with the Municipal Securities Rulemaking Board (“MSRB”) and the Securities and Exchange Commission (“SEC”); Ehlers Investment Partners, LLC (“EIP”), an investment adviser registered with the SEC; and Bond Trust Services Corporation (“BTS”), holder of a limited banking charter issued by the State of Minnesota.
This communication does not constitute an offer or solicitation for the purchase or sale of any investment (including without limitation, any municipal financial product, municipal security, or other security) or agreement with respect to any investment strategy or program. This communication is offered without charge to clients, friends, and prospective clients of the Affiliates as a source of general information about the services Ehlers provides. This communication is neither advice nor a recommendation by any Affiliate to any person with respect to any municipal financial product, municipal security, or other security, as such terms are defined pursuant to Section 15B of the Exchange Act of 1934 and rules of the MSRB. This communication does not constitute investment advice by any Affiliate that purports to meet the objectives or needs of any person pursuant to the Investment Advisers Act of 1940 or applicable state law. In providing this information, The Affiliates are not acting as an advisor to you and do not owe you a fiduciary duty pursuant to Section 15B of the Securities Exchange Act of 1934. You should discuss the information contained herein with any and all internal or external advisors and experts you deem appropriate before acting on the information.