Top Ten Takeaways

1. Consider whether the company should conduct its own internal investigation in response to a regulatory inquiry or enforcement action.
2. Determine whether it is in the company’s best interests to cooperate with the regulatory investigation or enforcement proceeding, what cooperation would entail, and what benefits could be expected.
3. Carefully consider who on the Board should take ownership of any internal investigation. This could be the Audit Committee, the Executive Committee, another standing Committee of the Board, or a Special Committee formed for this purpose, depending upon the circumstances. An independent director investigation may be necessary if there are serious allegations of wrongdoing by executive management.
4. ...

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