Although the SEC has been laser-focused on how advisers and broker-dealers manage and capture so-called “off channel” communications, firms should not expect a pass from the agency on other violations of SEC recordkeeping requirements – even when the problem is due to vendor error. The SEC charged J.P. Morgan Securities LLC (JPMorgan), which is registered with the SEC as both a broker-dealer and an investment adviser, with violating recordkeeping requirements after it inadvertently deleted millions of archived emails. The proceeding marks the third time the SEC has penalized JPMorgan over its handling of electronic communications. It is also an important reminder that firms remain ultimately responsible for the conduct of their vendors. This article details the circumstances giving rise to the proceeding and the terms of the settlement. See “SEC Penalizes Nine Advisers for Marketing Rule Violations in Ongoing Sweep” (Nov. 9, 2023); “SEC Remains Focused on Off-Channel Communications” (May 11, 2023); and “SEC and CFTC Penalize Broker-Dealers $1.8 Billion for Electronic Communications Recordkeeping Violations” (Oct. 27, 2022).