According to FINRA, SunTrust Robinson Humphrey, Inc., now known as Truist Securities, Inc., was censured and fined $150,000 for failing to establish and maintain a supervisory system reasonably designed to review correspondence and internal communications.

The firm was found in violation of its obligation to review electronic communications. First, the firm failed to review certain emails flagged for review by its automated system. The firm's email review system had a filter setting that limited the length of time flagged emails remained in the review set—emails not reviewed within two weeks dropped out of the supervisory review queue entirely. After becoming aware of this issue, the firm expanded the filter to three months, and later adopted a new system that prevented emails from dropping out of the review set.

Second, the firm failed to review certain Bloomberg email messages of associated persons. The firm failed to ensure that newly onboarded employees' Bloomberg email addresses were properly linked to the email review system, resulting in the firm failing to review messages from Bloomberg accounts of associated persons. The firm's written supervisory procedures required regular reviews for new Bloomberg addresses and submission of technology tickets to link Bloomberg accounts to employee profiles. However, the firm did not consistently implement this procedure, failing to include Bloomberg email addresses in the information technology profiles during the onboarding process.

After discovering instances of this failure, the firm did not implement new procedures until almost two years later. The firm eventually implemented a weekly reconciliation of email account information from Bloomberg to its email review system. Email review is a critical supervisory tool that helps firms detect misconduct, customer complaints, and regulatory violations. When firms fail to capture and review business communications, problematic conduct can go undetected. Investors should understand that proper email surveillance is an important protection against unsuitable recommendations, misrepresentations, and other forms of misconduct.