On November 8, 2021, the Supreme Court denied a petition for a writ of certiorari filed by registered broker-dealer Alpine Securities Corporation, which sought to overturn a civil enforcement action brought against the company by the Securities and Exchange Commission under Section 17(a) of the Securities Exchange Act of 1934 and Exchange Act Rule 17a-8 for failing to file certain Suspicious Activity Reports and omitting information from other SARs. Section 17(a) requires issuers to “make and keep … such records” and “make and disseminate such reports” as the SEC determines are necessary, and Rule 17a-8 incorporates the reporting and retention requirements of the Bank Secrecy Act by mandating that every registered broker or dealer subject to the requirements of the Bank Secrecy Act comply with the applicable reporting, recordkeeping and record retention requirements set forth in FinCEN’s regulations.