From September 2016 through November 2022, Ally failed to preserve at least 22.6 million business-related electronic communications, violating Securities Exchange Act of 1934 § 17(a), Exchange Act Rule 17a-4, and FINRA Rules 4511 and 2010. During the same period, Ally’s written supervisory procedures were not reasonably designed to ensure review of business-related electronic communications, and the firm failed to timely review at least 521,000 such communications, violating FINRA Rules 3110 and 2010. For these violations, Ally is censured and fined $850,000.