The allegations read: Without admitting or denying the findings, engelbach consented to the sanctions and to the entry of findings that he failed to enforce his member firm's wsps regarding the review and retention of electronic communications. The findings stated that the firm's wsps required that the firm's registered representatives forward all business related communications to the firm for review and retention. The wsps required that engelbach check representatives' email for compliance with this requirement during visits to representatives' offices and further required that he document his review of representatives' email and the outcome of each such review. However, engelbach failed to conduct any analysis to confirm that representatives were forwarding their business related communications to the firm, and engelbach did not document his review of representatives' emails, as required by the firm's procedures.
