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In-house Access Insight & Commentary for In-House Counsel Worldwide

Tag Archives: SEC

University Trustees Not “Obligated Persons” Under Dodd-Frank

Posted in Miscellaneous

Guest Bloggers: Jonathan Peri, Esq. is vice president and general counsel at Neumann University and can be reached at PeriJ@neumann.edu. Mark N. Suprenant, Esq. is the former general counsel and secretary of Wawa, Inc. and can be reached at marknsuprenant@gmail.com. Trustees and other leaders at not-for-profit colleges and universities can breathe a sigh of relief… Continue Reading

Congress and ACC Tackle SEC Whistleblower Bounty Program

Posted in Ethics & Compliance

  Today, the House Financial Services Committee heard testimony regarding its draft legislation rejecting the SEC and CFTC’s proposals to bypass internal compliance and reporting systems when rewarding prospective whistleblowers.  ACC filed a letter with the Committee, approving of the draft legislation (read the letter here).  In-house counsel who supervise internal compliance and reporting systems… Continue Reading

Is the SEC Blowing it for Whistleblowers?

Posted in Ethics & Compliance

  This morning, ACC registered what may be some of the most important comments the SEC considers this year. On behalf of 270 companies, we asked the Commission to think long and hard about rules they’ve proposed that will determine whether corporate compliance and reporting programs flourish or perish pursuant to whistleblower policies mandated by Dodd-Frank’s… Continue Reading

Punishing the Victims

Posted in Miscellaneous

I am sure that most of you have some passing familiarity with the dispute surrounding the bonus compensation of Merrill executives just prior to its sale to Bank of America. The claim was that Merrill had intended to pay its executives 5.8 billion dollars, 12% of the purchase price that Bank of America agreed to… Continue Reading