On April 14, 2025, the SEC issued an order (Order) denying motions made by 16 respondents (Respondents) in the hope of bringing about modifications and stays of settled orders against them over employees’ use of personal devices for business-related communications, i.e., off-channel communications, and related recordkeeping lapses. The Commission upheld earlier cease-and-desist orders against the 16 entities, keeping in place a range of compliance and reporting burdens imposed as part of an enforcement sweep against entities that failed to meet the SEC’s recordkeeping requirements. The motion was slightly atypical in that the Respondents argued that they were penalized more harshly than other firms caught later in the sweep. Commissioner Hester M. Peirce sympathized with them in her dissent, questioning the fairness of the settlements, especially given that the undertakings imposed on them would also have consequences for their FINRA membership. This article summarizes the settlements, the Respondents’ motions, the Order and Peirce’s dissent, and presents legal analysis of the decision and what it portends for regulatory enforcement in the coming months under new SEC leadership. See “Study Reports on Financial Industry Policies and Controls Around Electronic Communications” (Apr. 10, 2025).