SEC order on business communications kept off firm systems
Fund concerned: none named in the order. The matter concerns the adviser's own recordkeeping, not a specific fund, and none of the insurance-dedicated funds in this file is named.
The SEC found that from at least December 2019 Apollo Capital Management staff, managers among them, used messaging platforms that the firm had not approved for business, and that many of those messages were not preserved. The order found violations of the recordkeeping rule under Section 204 of the Advisers Act and a failure to supervise.
Apollo consented to the order, admitted the facts set out in it and acknowledged that its conduct broke the federal securities laws. The case was one of a series of similar SEC actions against advisers and broker-dealers over off-channel messaging.