In what appears to be the first action against a standalone registered investment adviser for failing to preserve off-channel communications, the SEC penalized Senvest Management, LLC. Along with paying a $6.5‑million civil penalty, the firm will, as in other similar proceedings, retain a compliance consultant to review its policies, procedures and practices for monitoring for and preserving off-channel communications. This article parses the alleged violations and the terms of the settlement, with commentary from Igor Rozenblit, managing partner at Iron Road Partners, who previously held several senior positions at the SEC, including Co‑head of the Private Funds Unit of the Division of Examinations. See “Latest SEC Sweep of Off‑Channel Communications Both Befuddles and Turns Up the Heat on Investment Advisers” (Apr. 10, 2024).