The undersigned trade associations (the “Associations”) respectfully submit this letter to the Securities and Exchange Commission (the “SEC” or the “Commission”) concerning the scope and application of the recordkeeping provisions of the Investment Advisers Act of 1940 (the “Advisers Act”) to text messaging and other electronic communications. Our members support SEC market oversight and share the view that the preservation of books and records in compliance with the SEC’s rules is critically important. As Chair Gensler recently acknowledged in public statements, the SEC’s recordkeeping rules have been an essential part of market integrity since the 1930s, and as technology changes, it is “even more
