Dodd Frank Whistle Blower Provisions

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WHISTLEBLOWING: RESPONDING TO THE

RACE TO REPORT February 3, 2011

REMINDERS

In order to receive participation credit, you must:

• Be appropriately registered for Webcast #21297within the BDO Online CPE Network

• Be logged in for the entire webcast

• Be responsive to at least 75% of all polling/reviewquestions

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Q&A FEATURE

• Technical questions may be submitted via the Q&AFeature on your screen. Time permitting, presenterswill respond to these at the end of the session.

• Please submit as much information as possible (e.g.,slide number reference, presenter, etc.).

• Submit Technological Support issues to LiveChatunder the “Support” tab.

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PRESENTERS

Select Experience

• Over ten years of experience in accounting for private and publiclytraded businesses.

• Member of the Financial Reporting Disputes and Investigationsgroup, encompassing securities litigation, accountants’ professionalliability, and corporate internal investigations.

• Assists organizations and their counsel with matters involvingalleged financial statement irregularities and management fraud aswell as fraud perpetrated by rogue employees.

• Participated in a number of internal investigations and mattersinvolving whistleblower allegations.

•

Nicole Sliger,

CPA, CFE, CFF

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prepare for depositions of witnesses concerning testimony thatinvolves the application of generally accepted accounting principles(GAAP) and generally accepted auditing standards (GAAS).

Education

B.S., Accounting, The College of New Jersey

DirectorBDO Consulting

New York, NY

[email protected]

212-885-8062



PRESENTERS

Select Experience• Focuses on securities transactions and M&A transactions,

restructurings and bankruptcies, and general corporate matters

• on offerings of diverse types of securities, medium-term noteprograms, 144A offerings and debt tenders, and M&A transactions

• Regularly advises on SEC reporting, disclosure and corporategovernance issues

• Recently served as Chair of the Securities Regulation Committeeand Chair of the Financial Reporting Committee of the New YorkCity Bar

Education

N. Adele HoganCadwalader, Wickersham &

Taft LLP

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J.D., Cornell Law School

B.A., Cornell University, College Scholar

New York, New York

[email protected]

212-504-5586

917-402-3688

PRESENTERS

Select Experience

• Twenty-five years of experience assisting clients with securitieslitigation matters and investigations involving alleged financialstatement and management fraud, as well as representingaccounting firms against claims arising from professional liabilityissues.

• Co-National Director of the Securities Litigation & RegulatoryEnforcement practice. He is also the lead Partner on Credit CrisisLitigation matters.

• Led numerous high profile securities litigation engagements andinvestigations.

• Testified before various courts, including the International Court of

Anthony M. Lendez,

CPA, CFE, CFFPartner

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Arbitration and the American Arbitration Association, and haspresented investigation results to the staff of the Securities andExchange Commission and various committees.

Education

B.S., Accounting, Long Island University, (C.W. Post Center),summa cum laude

BDO ConsultingNew York, NY

[email protected]

212-885-8025



PRESENTERSSelect Experience

• Over twenty years experience in Risk Management and Compliance

• His writings have been featured in National Underwriter Magazineand Risk Management Magazine and his commentary on the Foxus ness anne

• Led the development of an integrated Governance, Risk andCompliance (GRC) platform that brings together policymanagement, compliance training/certification, issue/incidentdetection, event/case management, correctiveaction/remediation management and businessintelligence/analytics

• Featured speaker at conferences hosted by the Institute ofInternal Auditors (IIA), the Risk and Insurance Management Society

Luis RamosChief Executive Officer

The Network, Inc.

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, e ssoc a on o o ege an n vers y u ors

• Provides over 3,000 companies, including nearly 50% of theFortune 500, with GRC related solutions

Education

B.S., University of Central Florida, with a concentration in businessand risk management

Norcross, Georgia

[email protected]

770-409-5011

PROGRAM OBJECTIVES

• Review the Dodd-Frank Act’s whistleblower provisions, theproposed SEC rules, some criticisms of these proposed rules, andthe related amendments to the U.S. Sentencing Guidelines

• Discuss the impact on companies’ compliance/ethics programs,boards and audit committees, and employees

• Provide practical guidance on how to enhance current ethics andcompliance programs in response to the new legislation to:

• Encourage early internal reporting of potential wrongdoing

• Enable companies to conduct thorough and timely

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investigations of allegations• Assist with prudent decisions regarding self-reporting

• Comply with the new U.K. Bribery Act and increased ForeignCorrupt Practices Act (FCPA) enforcement



AGENDA

• Key Components

- Dodd-Frank Act

- SEC W ist e ower Program

- Recent Amendments to the U.S. Sentencing Guidelines

- U.K. Bribery Act and FCPA Enforcement Activities

• Current State of Affairs

• How Companies Can Respond

- Miti ate Im act on Com liance & Ethics Pro rams

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- Enhance Existing Internal Reporting Systems

-Expedite the Process to Investigate & Possibly Self-Report

• Questions & Comments

KEY COMPONENTSDODD-FRANK ACT

• The Dodd-Frank Wall Street Reform and ConsumerProtection Act was signe into aw on Ju y 21, 2010

• Whistleblower provisions are designed to incentivize andprotect individuals who voluntarily provide “originalinformation” to the SEC

• Significantly expands the scope of whistleblower claimsand applicable entities from Sarbanes-Oxley (SOX)

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KEY COMPONENTS

DODD-FRANK ACT

Eligibility for awards

• Original Information – Must be:

- Derived from independent knowledge or analysis

- Not known to the SEC from other sources

- Not exclusively derived from an allegation made in a judicialor administrative hearing, other governmental proceeding,investigation or news media

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- Voluntarily provided by whistleblower

•

Successful SEC enforcement action with > $1M in sanctions• 90-Day Grace Period


Substantial monetary awards

• 10-30% o t e sanctions impose over 1 mi ion

• Amount varies based on a number of criteria including:

- Significance of information to the successful enforcement andimposition of monetary sanctions

- Degree of assistance provided by whistleblower

- Interest of SEC/CFTC in deterring securities and commodities

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law violations- Whether an award enhances the SEC’s or CFTC’s ability to

enforce securities and commodities laws, protect investors,and encourage the submission of high-quality tips



KEY COMPONENTS

DODD-FRANK ACTExpanded scope of claims and applicable entities

• Relates to any potential violation of securities laws, including FCPA

- Previously only insider trading violations could be the basis for an awardunder the SEC’s previous program

- For first time – applies to Commodity Exchange Act (CEA) (violations overcommodity futures trading is overseen by Commodity Futures TradingCommission (CFTC))

• Any action brought by the SEC/CFTC under the Securities Act of 1933,the Securities Exchange Act of 1934, the Investment Advisers Act of

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,

• Applicable to both public AND private companies including:

- Statistical rating organizations- Subsidiaries and affiliates whose financial information is included in

consolidated financial statements of a publicly-traded entity


Additional anti-retaliation safeguards and enhanced

protections

• Private cause of action for individuals discriminatedagainst by employers due to whistleblowing

• Applies to anyone who provides information on apotential violation, regardless of whether a securitiesor commodities law violation is ultimately determined

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• Remedies include double back-pay (but not for CEAwhistleblowers) with interest, restatement of senioritystatus, and attorneys’ fees



KEY COMPONENTS

DODD-FRANK ACTLengthened reporting period for whistleblower retaliation

claims

• Originally under SOX, whistleblowers had 90 days after the date of thealleged retaliatory conduct or after the individual became aware ofthe alleged retaliatory conduct to bring a complaint – Now it’s 180days

• Under Dodd-Frank, up to a maximum of ten years for SEC retaliationclaims

- - -

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- Three years after facts material to the right of action are known or

reasonably should have been known by the employee• For CTFC retaliation claims, up to a maximum of two years

• Reporting pre-Dodd-Frank Act conduct may still qualify for award

KEY COMPONENTSSEC WHISTLEBLOWER OFFICE

• Office to be created as part of the Dodd-Frank Actput on o ue to u getary issues

• Expands and remakes the SEC’s previous program

• Timeline of events

- November 3, 2010 – Proposed rules issued

- December 17, 2010 - Comment period ended

- A ril 17 2011 - Final rules must be issued

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POLL

What are your initial thoughts on the SEC’s proposedwhistleblower guidelines?

A. The Proposed Rules are acceptable as initiallyissued.

B. With a few minor tweaks, the Proposed Rulesshould be an effective way to increase reports ofsecurities violations.

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. .

D. Even with significant rework, the Proposed Rules

will not be an effective way to increase reports ofsecurities violations.

KEY COMPONENTSSEC WHISTLEBLOWER PROGRAM

Criticisms of proposed rules

• Permit awards to culpable individuals, and thus, mayreward misconduct

- Awards to whistleblowers who engage in the wrongdoing arenot eligible if they are convicted of a criminal offense inrelation to the wrongdoing

- While fines based on conduct that a whistleblower directed,

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p anne or n a e are no nc u e n o a awar orpurposes of calculating whistleblower’s potential award,culpable individuals are still eligible, and misconduct couldthus be condoned



KEY COMPONENTS

SEC WHISTLEBLOWER PROGRAM


• Large incentive created for employees to bypass internalreporting systems

- Enormous awards potentially available under the new program

Some recent enforcement actions have resulted in sanctionsexceeding $100 million

- Proposed Rules contain no requirement that an individual

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utilize an internal reporting system first

SEC commentary on rules states that the agency mayconsider internal reporting as a factor in determining ahigher percentage



• 90-day grace period creates a deadline for “voluntary”disclosures

- Attempt by the SEC to avoid discouraging the use of internalreporting systems, but creates no affirmative incentive foremployees to use such systems

- 90 days is rarely enough time to properly investigate an

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a ega on o emp oyee m scon uc ; corpora ons may eforced to self-report without knowing all the facts relating tothe potential violation



KEY COMPONENTS

SEC WHISTLEBLOWER PROGRAM


• Lack of clarity in exclusion from eligibility of individuals withlegal or compliance responsibilities

- Such personnel are generally excluded from eligibility in mostcircumstances, but may be eligible in cases of “bad faith” or wherethe company fails to report to the SEC in a “reasonable time”

• Do not address SEC procedures for sharing information withaffected com anies to ermit them to address re orts internall

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- Commentary states the agency will share information “inappropriate cases,” but does not provide further detail



• Provide no guidance on the anti-retaliation provisions ofDodd-Frank

- Dodd-Frank creates cause of action for individuals thatsuffer employment discrimination “because of”whistleblower status

- An employee may violate code of conduct by failing to

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repor m scon uc n erna y, u never e ess e a“whistleblower” under the proposed rules

- Employers risk litigation by enforcing code of conduct insuch situations



KEY COMPONENTS

RECENT AMENDMENTS TO THE U.S. SENTENCING GUIDELINES

Provide increased opportunity for companies to reduce the

pena es mpose or secur es aw v o a ons y:

• Having an effective compliance and ethics program in place

• Including anti-retaliation provisions in compliance programs

• Incorporating direct reporting obligations between the headof the compliance program and the Board of Directors orAudit Committee

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• Assessing and reporting on the implementation and

effectiveness of the compliance and ethics program at leastannually

KEY COMPONENTSU.K. BRIBERY ACT

Provides more stringent rules than those established in the

. .

• Applies to all companies with a business presence in the U.K.

• Effective April 2011 (Delayed – Perhaps until three months

after application guidance is established)

• Failure to prevent bribery, not only the act of bribery itself,will now be unishable b law

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• Companies can protect themselves from liability byimplementing “adequate procedures”



KEY COMPONENTS

U.K. BRIBERY ACT

Differs from the Foreign Corrupt Practices Act (FCPA) in

severa ways – e . . r ery c :

• Makes no exception for small facilitation payments

• Establishes liability on behalf of companies for the failure toprevent bribes, even if bribes were given without theknowledge of the company

• Ex licitl rohibits the briber of rivate citizens not ust

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government officials

•

Includes criminal penalties of up to ten years in prison, asopposed to five years as stipulated by the FCPA

KEY COMPONENTSU.K. BRIBERY ACT

Establishes draft guidance on six principles intended to

1) Risk Assessment – Companies must identify possible risks,including a deficiency of employee knowledge of briberyregulations or a lack of clear policies regarding potentiallyconfusing issues (e.g., gifts and travel expenses)

2) Top Level Commitment – Top management must show their

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commitment to fair business practices and make it a priority tofacilitate a “zero tolerance” environment

3) Due Diligence – Companies should have comprehensiveknowledge of third parties with whom they are doing business



KEY COMPONENTS

U.K. BRIBERY ACT

Establishes draft guidance on six principles intended to

4) Clear, Practical and Accessible Policies and Procedures –Companies should establish mechanisms to prevent briberythroughout the company

5) Effective Implementation – Must be clearly outlined andembedded throughout the company including training

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6) Monitoring and Review – Internal checks and balances andexternal verification must be undertaken to ensure on-goingcompliance with bribery regulations, even as the riskenvironment undergoes changes

KEY COMPONENTSFCPA ENFORCEMENT ACTIVITIES

The SEC released new enforcement criteria in 2010:

• The Department of Justice (DOJ) has recently reemphasized itscommitment to the FCPA, wanting to usher in a “new era” ofenforcement

• The DOJ aims to be more “aggressive” in its enforcement andprosecutorial efforts

• The SEC has also appointed new leadership to lead the FCPA

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Unit – Cheryl J. Scarboro, Chief of the FCPA Unit



KEY COMPONENTS

FCPA ENFORCEMENT ACTIVITIES

Recent trends in FCPA enforcement:

• Increased Number of Prosecutions – Average number of FCPAenforcement cases per year increased 400% from approximately10 cases between 2004-2006 to 40 cases in 2009 alone

• Increased Penalties – In the past year, the DOJ has imposedcriminal penalties totaling over $1 billion, up from just $11million in 2004

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• Longer Sentences for Individuals – In April 2010, the longestsentence was handed down - 87 months in prison!

• Focus on International Cooperation – DOJ is committed toestablishing effective partnerships with overseas agencies

POLL

Is your current compliance/ethics program sufficient toencoura e n erna repor n y emp oyees

A. Yes, absolutely

B. Probably

C. Marginally sufficient

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. ,

E. Not sure / Not applicable

F. I don’t want to answer this question – Plead the 5th!



CURRENT STATE OF AFFAIRS

WHERE DO WE GO FROM HERE?Impact on boards and audit committees

• May compel hasty self-reporting of potential wrongdoingwithout vetting out facts

• May require increased training on Dodd-Frank’swhistleblower provisions, U.K. Bribery Act, and FCPAprovisions

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• May require increased communications to include the “toneat the top” as one of compliance

CURRENT STATE OF AFFAIRSWHERE DO WE GO FROM HERE?

Impact on compliance/ethics programs

internal compliance/ethics programs and report directly tothe SEC

• Could undermine internal programs by reducing theeffectiveness of the company’s existing procedures forindentifying, investigating and responding to potential

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• Whistleblowers might be encouraged to wait until apotential problem grows into a larger issue to increasetheir chance of collecting a more significant award



CURRENT STATE OF AFFAIRS

WHERE DO WE GO FROM HERE?Impact on employees

• Provides greater retaliatory protections when reportingwrongdoing to the SEC

• May need to restore faith in the effectiveness of thecompany’s processes to entice them to report internally

• May require encouragement to use internal reporting

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• May affect employment agreements

POLL

To date, how has your company prepared itself to respond tonew legislation / proposed rules?

A. We have discussed at length and in significant detail

B. We have discussed briefly at a high-level

C. We have not held any discussion at this time

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D. Not sure / not app ica e



HOW COMPANIES CAN RESPOND

MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS

Review and update relevant aspects of existing compliance

• Employee codes of conduct

• Training programs – Conduct early and often, live-based withmultiple mediums and interactive discussions

• Internal reporting systems - Encourage use; bounties

• Clear procedures for investigating reports

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• Proce ures or a ressing require reme iation

• Post notices on intranet sites and provide compliance materials

and policies online

HOW COMPANIES CAN RESPONDMITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS

Implement policy enhancement suggestions and internal

Companies may consider:

• Drafting requirements for simultaneous disclosure clauses inemployment contracts and compliance policies

• Developing “internal bounty programs”

• Promoting recognition of tips that were awarded

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• ncorpora ng su s an ve e cs me r cs n o corpora ecompetencies and performance evaluations




MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMSImplement policy enhancement suggestions and internal

Companies may consider:

• Lengthening document retention policies

• Amending vendor and supplier contracts to have vendors andsuppliers notify the companies of any suspected wrongdoing

• Obtaining quarterly certifications from employees stating that no

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HOW COMPANIES CAN RESPONDMITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS

Develop anti-retaliation policies and procedures

• Ensure current policies are updated for all new anti-retaliation protections

• Educate employees on the existence of such policies

• Entice employees to come forward internally

• Communicate regularly with employees on anti-retaliation and other com liance olicies

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MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS

Heighten the visibility and availability of compliance and

• Involvement of top management in communications toadd creditability and emphasize importance

• Training programs

• Availability of hotline programs

– 24-7/365 Access

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- Cover all geographic/international locations

-

Be aware of language barriers- Expand reach to third parties such as customers, suppliers,

business partners, competitors, etc.

POLL

How often does your company provide training or

A. Frequently (more than twice a year)

B. Once annually

C. Very seldom

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.

E. Not sure / Not applicable




ENHANCE EXISTING INTERNAL REPORTING SYSTEMS

Assess functionality of current internal reporting systems

• Companies should ask themselves:

- Do employees utilize the existing system?

- How does our hotline compare to others in the industry?

• Perform periodic reviews (at least annually)

• Assess and evaluate by:

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- Anonymous surveys

-

Benchmarking- Focus groups

- Exit and other interviews

- Feedback from reporting system users- Incident logs

HOW COMPANIES CAN RESPONDENHANCE EXISTING INTERNAL REPORTING SYSTEMS

Employ effective internal reporting mechanisms

• Evaluate and update internal compliance programs

• Ensure that any reports received from employeesthrough internal mechanisms remain confidential(and this is clear to employees), and whereappropriate, lead to prompt investigation anddisciplinary action

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• Elicit trust by exhibiting a corporate culture thattakes claims of fraud and other potential violationsseriously




ENHANCE EXISTING INTERNAL REPORTING SYSTEMS

Encourage board & audit committee involvement

• Revisit corporate culture to ensure it promotes anopen, honest and candid environment

• Review current policies for unlawful acts

• Request regular reports on hotline complaints,ongoing analyses/investigations and resolutions

• Reiterate im ortance of internal re ortin and

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participate in regular training on compliance/ethics

programs

HOW COMPANIES CAN RESPONDENHANCE EXISTING INTERNAL REPORTING SYSTEMS

Utilize live, skilled interviewers to handle call intake

• e er a e o e c comp e e an re evaninformation regarding allegations

• Ensure interviewers have the requisite language skillsto accommodate ethnic backgrounds andinternational callers

• Assist with preserving anonymity and confidentiality,

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especially if third-party, which, in turn, willencourage use of internal system




ENHANCE EXISTING INTERNAL REPORTING SYSTEMSProvide “true” confidentiality

• r g n o ca s s ou rema n secre nc u ngincoming numbers or Caller ID)

• Gender should not be revealed

• Unique ID code should be provided to caller to follow-up on his/her report or to report more informationabout their claim at a later date

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• Secure data and maintain integrity of access tointernal reporting systems

POLL

How well would you rate your company’s internal

A. Very effective

B. Somewhat effective

C. Not nearly as effective as it should be

D. Not sure / Not a licable

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EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORTEstablish & execute prearranged investigative procedures

to evaluate tips

• Implement clear lines of reporting from hotline to seniormanagement, the Board and the Audit Committee

• Consider developing a report distribution matrix

• Employ controls to reduce risk of management override

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• Create a clear communication process for status reports

•

Establish a disciplinary committee to assess remedialactions

HOW COMPANIES CAN RESPONDEXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT

Perform a preliminary assessment of the allegations

• Gain an understanding of the scope, origin and reachof the alleged misconduct

• Determine the nature and amount of resourcesneeded to carry out an investigation (if needed)

• Identify legal, accounting, and investigative experts

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upfront




EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORTPlan and execute an investigation, if warranted

• the investigation

• Identify specific objectives, responsibilities and workproduct to be produced upfront

• Limit continuation of alleged misconduct

• Consider using outside counsel as appropriate

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• Investigate all internal whistleblower reports thoroughly,including anonymous reports

• Document company’s receipt, review of, and response toeach complaint/report

HOW COMPANIES CAN RESPONDEXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT

Consider following-up on allegations by:

• n orm n w s e owers a ou e nves a on sprogress and address any additional concerns

• Publicizing internally the results of the company’s reviewand response where violations are found

• Mitigating possible future whistleblowers, when employeeseparates from the company

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• Analyzing trends in claim volume by type of claim andfrequency and benchmark to industry to monitor forsimilar complaints of past allegations




EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORTDevelop procedures to address reports to the SEC

• u ne spec c proce ures or sen or mana ers o rap yrespond to the SEC in the event of a whistleblowercomplaint

• Devise a document production process in the eventrequests are made by the SEC

• Arrange resources in anticipation of independent internal

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investigations

• Identify protocols for notifying third parties such asauditors, investors and the public

POLL

Does your company have appropriate prearranged

A. Yes, very much so

B. Somewhat

C. No, not at all

D. Not sure / Not applicable

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EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORTImplement mechanisms that result in more thorough self-

• Requires careful evaluation to determine the most prudentcourse of action

• Keep in mind the strict time limitations with the 90-Daygrace period

• Consider remediation and disciplinary actions for those

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nvo ve n poss e v o a ons

• Be mindful of “credits” offered by the SEC for cooperation

• Be careful not to self-report prematurely before thealleged violation can be investigated adequately

POLL

After listening to our discussion today, do you feelopportunities exist to enhance performance of yourcompany s nterna comp ance an et cs programs

A. Yes, very much so

B. Somewhat

C. No, not at all

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.



POLL

After listening to our discussion today, what are yourthoughts now on the SEC’s proposed whistleblower

A. The Proposed Rules are acceptable as initiallyissued.

B. With a few minor tweaks, the Proposed Rulesshould be an effective way to increase reports ofsecurities violations.

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. e ropose u es requ re s gn cant rewor .

D. Even with significant rework, the Proposed Ruleswill not be an effective way to increase reports ofsecurities violations.

QUESTIONS & COMMENTS

? ? ?

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HELPFUL RESOURCES

- BDO Practice Aid: Strengthening Corporate Governance: Effective Mechanisms

for Reporting, Investigating and Remediating Fraud

htt ://www.bdo.com/acsense/ racticeaids.as x

- Ac’sense 2010 Internal Investigations

http://www.bdo.com/acsense/events/InternalInvestigations.aspx

- BDO Consulting Thought Leadership

http://www.bdoconsulting.com/resources/thought-leadership.aspx

- Cadwalader, Wickersham & Taft LLP

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http://www.cadwalader.com/

- The Network, Inc.http://www.tnwinc.com/index.aspx

PRESENTER CONTACT INFORMATION

Today’s Presenters:

N. ADELE HOGAN [email protected]

ANTHONY M. LENDEZ [email protected]

LUIS RAMOS [email protected]

NICOLE SLIGER [email protected]

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ADDITIONAL AC’SENSE INFORMATION

Ac’senseSM Programs and Website:http://www.bdo.com/acsense/

’-shortly at:http://www.bdo.com./acsense/events/Whistleblowing.aspx

Upcoming webcast:

Executive Compensation: Impact of the Dodd-Frank Act and

Next Ste s – Februar 23 2011

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http://www.bdo.com./acsense/events/ExecutiveCompensa

tion.aspx

CPE CERTIFICATES

Certificates will be processed and will be accessible byparticipant for printing as follows:

-.http://university.learnlivetech.com/BDOonline after the session iscompleted and clicking on My Learning - Completed Items. Underthe Certificate column, click the Print button beside the completedwebcast.

2. Group participants - After receipt and processing of submitted groupsign-in sheets to [email protected] , group participants will beproctored into Learn Live and will be notified via e-mail when they

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can retrieve their certificates, following the steps above.3. Sign-in sheets may be downloaded from the following:

https://university.learnlive.com/content/public/1029/accessinstru

ctions/CPE%20Attendance%20Sheet.doc



EVALUATION

• We continually try and improve upon ourprogramming an appreciate constructive ee ac

• Following the program, we will be sending out athank you e-mail that contains a link to a briefevaluation

• Thank you in advance for you consideration!

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THAT CONCLUDES TODAY’S PROGRAM.

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Thank you for attending!

Documents

Dodd Frank Whistle Blower Provisions