# Text Message Archiving for SEC and FINRA Recordkeeping Archive SMS, MMS, and RCS text messages from managed Android devices, alongside WhatsApp, iMessage and Signal. Designed against SEC 17a-4 and FINRA 4511. Source: https://commacompliance.com/sms-compliance-archiving Last updated: 2026-09-23 --- Text Message Archiving # Your firm has a texting policy. That's not the same as having the texts. SMS, MMS, and RCS live on the carrier network, outside the systems your firm already archives. Comma captures them at the source. They land in the same archive as WhatsApp, iMessage, and Signal. [Book a demo](/get-in-touch) Built to the standards regulators ask about - SEC 17a-4Books & records - SEC 17a-3Supervision - FINRA 3110Review & retention - FINRA 4511Books & records - CFTC 1.31Commodity records - MiFID IIEU comms recording - FCA SYSC 10AUK taping - GDPRData protection On this pageWhat is text message archiving? - [What is text message archiving?](#what-is-text-message-archiving) - [What the rules require](#what-the-rules-require) - [How Comma captures a text message](#how-comma-captures-a-text-message) - [What this does not cover](#what-this-does-not-cover) More than [a quarter of advised clients](https://go.ycharts.com/hubfs/YCharts_Advisor_Client_Communication_Survey_2024.pdf) want their advisor’s market perspectives delivered by text. And a text is the message that gets read: [97% of SMS messages are read within 15 minutes of delivery](https://www.redeye.com/resources/sms-marketing-vs-email-marketing-who-wins-the-battle-for-effectiveness/). Still, many firms’ written policies say: no texting clients. Since 2021 the SEC, FINRA and the CFTC have issued more than $3.2 billion in off-channel penalties, almost all of it on conversations that never reached a supervised system. Text messages can be among the more difficult communications to account for. An advisor confirms a trade by text. A client texts “go ahead” instead of replying to the email. None of it touches a mail server, a Bloomberg terminal, or an app with an API anyone can connect to. ## What is text message archiving? Text message archiving is the practice of capturing, retaining, and supervising business communications sent as SMS, Multimedia Messaging Service (MMS), or Rich Communication Services (RCS) messages, in a form a regulator can later inspect. It is not the same problem as archiving WhatsApp or Signal. A text message has no API and no linked-device option to connect with. It is delivered by a carrier to whichever device holds the SIM for that number, and it stops there. So text message archiving comes down to one question: **who controls the endpoint the message is delivered to?** Either the business manages the device, or the business owns the number. ## What the rules require Regulated industries with business-communication rules typically require all business communications to be captured and archived. Text messages are no different. Which rule you answer to depends on what you do. - **Broker-dealers and advisers.** FINRA-compliant text message archiving comes down to three rules: [FINRA Rule 4511](/regulations/finra-rule-4511) to preserve books and records in a format regulators can inspect, [SEC Rule 17a-4](/regulations/sec-17a-4) for retention and accessibility, and [FINRA Rule 3110](/regulations/finra-rule-3110) for supervisory procedures matched to the channels your team actually uses. - **Public agencies.** A text about public business is a public record under state open-records law, on the same retention schedule and open to the same disclosure request as an email. See [communications archiving for state and local government](/government). - **Healthcare.** A text carrying patient information is protected health information wherever it lives, and the HIPAA Security Rule follows it onto the phone. See [communications archiving for healthcare](/healthcare). - **UK firms.** [FCA SYSC 10A](/regulations/fca-recordkeeping) requires recording of client-related communications and reaches the channels staff actually use, texting included. - **EU firms.** MiFID II requires firms to record communications intended to lead to a transaction, in whatever medium they happen. - **Anyone facing litigation.** Once litigation is reasonably anticipated, a text message is electronically stored information subject to preservation. Losing it is a spoliation problem rather than a recordkeeping one. See [e-discovery and communications investigations](/e-discovery). Nothing in any of them turns on the channel. A text confirming an order is a record for the same reason an email confirming an order is a record. What changes is the difficulty of capture, and difficulty has never been a defence. Comma’s archive is designed against SEC 17a-4, FINRA 4511, CFTC 1.31, and MiFID II electronic-recordkeeping requirements. ## How Comma captures a text message ### The Comma Messages Archiver on a managed Android device Where the firm owns the phone, Comma captures each message as the phone receives it and writes it to the same archive as your other channels. What you get back is the conversation as it happened: the thread, the attachments, the timestamps, the group it belonged to. This is the only path that covers RCS. What lands in the archive: - SMS, including long multipart messages - MMS media - RCS 1:1 and group chats, with attachments, edits, and reactions - History already on the phone at setup, controlled by a backfill window you set per device Captured SMS and MMS are searchable alongside your other channels and can be exported for an exam, an audit, or a production request. Two things to know before you scope a rollout. The phone must be company-owned and fully managed: work profile, BYOD, and COPE devices are out of scope. Provisioning runs through your MDM, whichever platform you use. Capture is disclosed on the device. While archiving is active the phone shows a persistent “archiving for compliance” notification naming your organization, and the first launch shows a plain-language summary of what is captured. Each enrolled device is listed in an admin roster and can be revoked individually, which stops its archiving at once. Enrollment is cryptographically bound to the device it was issued for. Setup is documented in full: [Setting Up RCS/SMS Archiving (Android)](https://docs.commacompliance.com/getting-started/rcs-android-setup/). ### Personal devices Where the phone is personal rather than company-owned, a hosted business number is available on request. [Talk to us](/get-in-touch). ## What this does not cover Being specific about coverage is more useful than claiming all of it. - **Personal phones.** The Android path needs a company-owned, fully managed device. - **Anything outside Android.** [iMessage is a separate channel](/imessage-compliance) with its own connector. - **RCS anywhere else.** The managed Android path is the only route to it. ## Text message archiving, compared Text message archiving, compared feature-by-feature comparison | Capability | Comma | Typical competitor | | --- | --- | --- | | RCS capture, including group chats and reactions | ✓ | — | | Permanent business number that survives a phone change | On request | SIM-bound | | Capture disclosed to the user on the device | Persistent notification | Often silent | | Same archive as WhatsApp, iMessage, and Signal | ✓ | Separate connector fees | ## Frequently asked questions Does FINRA require archiving text messages? Yes, where the text is a business communication. FINRA Rule 4511 and SEC Rule 17a-4 require firms to preserve business records regardless of the channel they were sent on. A text confirming an order or giving advice is a record on the same terms as an email doing the same thing. FINRA has made off-channel communications a standing examination priority, and regulators have issued more than $3.2 billion in penalties since 2021 to firms whose records showed employees used unsupervised channels anyway. Can you archive text messages on an employee's personal phone? Not on the managed Android path, which requires a fully-managed company-owned device. Where the phone is personal, a hosted business number is available on request: the employee uses that number for business texting and their personal number stays out of scope entirely. Talk to us about whether it fits your rollout. What is the difference between SMS, MMS, and RCS? SMS carries plain text and is the oldest of the three. MMS adds media such as photos and video. RCS — Rich Communication Services — is the SMS successor on Android, used by carriers like T-Mobile and through Google Messages, and it adds read receipts, typing indicators, group chats, and rich attachments. Comma captures all three in the same capture on the managed Android path. Does archiving text messages require MDM? Only on the managed Android path, and there it is a hard requirement: the device must be fully-managed (device-owner), and your MDM delivers the managed-configuration key that wires Google Messages to the archiver. Work profile, BYOD, and COPE devices are not supported on that path. The hosted business number path requires no MDM and no device management at all. ## The channel everyone assumes is covered. Book a 20-minute walkthrough. [Book a demo](/get-in-touch)[Pricing](/pricing) Related reading - [Consumer Messaging Compliance Archiving](/consumer-messaging-compliance-archiving) WhatsApp, iMessage, and Signal: the app-layer channels, captured off-device. - [iMessage Compliance Archiving for SEC & FINRA](/imessage-compliance) Point-of-delivery iMessage capture, independent of iCloud. - [BYOD Messaging Compliance](/byod-messaging-compliance) What can and cannot be captured when the phone belongs to the employee. - [FINRA Rule 4511: Books and Records](/regulations/finra-rule-4511) The recordkeeping obligation text messages fall under. - [We Open-Sourced the Android App That Archives Employee Texts](/post/open-sourcing-android-sms-rcs-capture) The capture code for the managed Android path, published on GitHub. - [Platform Integrations](/platform-integrations) The 40+ channels Comma captures, in one place. On this page - [What is text message archiving?](#what-is-text-message-archiving) - [What the rules require](#what-the-rules-require) - [How Comma captures a text message](#how-comma-captures-a-text-message) - [What this does not cover](#what-this-does-not-cover)