Recently, the SEC announced charges and a settlement with a Texas-based registered investment adviser (the respondent) after finding that from at least May 2018 through October 2021, its personnel allegedly failed to follow record-keeping requirements mandated by the Investment Advisers Act of 1940. Specifically, the firm’s personnel allegedly used personal devices to communicate business via personal text messages, which were not retained as required by law. This failure was discovered during a subpoena response related to another entity. Because the respondent self-reported the violations, took prompt actions and cooperated with the SEC, the SEC did not impose a civil penalty.