With the SEC continuing to scrutinize firms’ recordkeeping and communication practices, off-channel communication remains one of the most persistent and high-stakes challenges facing compliance teams today. That’s why Quest CE partnered with archiving solution provider MirrorWeb to host a timely webinar, “Demystifying On- and Off-Channel Communications.”
The session featured Allison Byrne, Director of Sales and Marketing at Quest CE, and Jamie Hoyle, Vice President of Product at MirrorWeb, who together unpacked what regulators are asking for, where firms remain vulnerable, and how to bridge the gap between policy and behavior. From common misconceptions about archiving to real-world behavioral challenges, the webinar offered clear, actionable insights for building a more defensible approach to communications oversight.
Below is a recap of the key questions and insights from the conversation.
Q: What’s a common misconception about archiving?
Many firms still assume archiving is a purely technical task when in reality, it requires a balance of policy, training, and vendor understanding.
Common concerns raised by compliance officers include:
- Privacy laws that vary by state
- How archiving works on personal devices
- Employee resistance to monitoring
It was noted that many firms come into vendor discussions expecting an “easy button” solution—when in fact, meaningful compliance depends on internal governance and adoption. Technology alone doesn’t solve the problem without structure behind it.
Q: What can archiving vendors do, and what can’t they?
There was an important reminder that archiving vendors aren’t magic wands. They can capture and retain messages, but firms must be prepared to provide proper access, permissions, and internal alignment for tools to function as intended.
Too often, firms think they’re covered because a solution is “turned on,” when in reality, their reps are still communicating outside monitored systems. The session emphasized that archiving is most effective when layered with training, policies, and behavioral nudges.
Q: What do regulators actually want to see during exams?
Attendees were encouraged to look at archiving from the examiner’s point of view. Regulators aren’t just asking if firms have a solution—they’re digging into how it’s configured, how consistently it’s used, and whether there’s oversight.
During exams, firms should be prepared to show:
- Clear archiving procedures
- Proof of retention for both on- and off-channel systems
- Logs or evidence of supervision activities
Compliance posture matters as much as the technology in place. A risk-based, well-documented approach can go a long way in showing good-faith efforts.
Q: How does archiving differ for on- vs off-channel communications?
The discussion shifted to how oversight can vary dramatically depending on the platform. While firms often assume their “on-channel” tools like Teams, Slack, or email are fully locked down, that’s not always the case. Many of these tools still offer side channels or unmonitored functionality.
On the other end of the spectrum, “off-channel” tools like WhatsApp, Signal, and iMessage are far more difficult to track—especially when disappearing messages or personal devices are involved.
It was stressed that firms should avoid a one-size-fits-all approach and instead prioritize based on usage and risk. Focus first on high-risk tools that are widely used, then expand oversight from there.
Q: Why do reps keep using off-channel tools despite policies?
Even with the right tools in place, behavior often doesn’t follow. The conversation turned to the human side of compliance—why reps continue to default to texting or using familiar consumer apps.
Key behavioral drivers include:
- Convenience and speed
- Client expectations
- Lack of awareness or buy-in
Policies are essential, but they’re not enough on their own. Firms need to invest in training, implement nudges within workflows, and create compliant solutions that don’t disrupt daily routines. Cultural change takes time, but it’s critical to reduce off-channel risk.
Q: Where are firms still vulnerable?
In wrapping up, the conversation highlighted some of the most common blind spots that can expose firms to regulatory scrutiny:
- Assuming tech covers everything without validating its effectiveness
- Overlooking app features like disappearing messages or auto-deletes
- Failing to address behavior even after tools are deployed
Ultimately, defensible archiving requires more than technology. It demands clear policies, ongoing education, real-world testing, and a willingness to evolve as the communication landscape changes.
Compliance Takeaway
This webinar made one thing clear: compliance with communication rules isn’t just about archiving—it’s about building a culture of awareness, accountability, and adaptability. Firms that blend behaviorally aware training, defensible tech policies, and consistent oversight will be best positioned to navigate what’s ahead.
