In an article published in the May 2017 issue of the Association of Corporate Counsel Docket, Arnall Golden Gregory’s Senior Counsel David Felt and FactorTrust Inc’s general counsel and CCO Barbara Sinsley provide guidance on how to effectively manage a government investigation.
Setting: You are the in-house counsel. Your large financial services company takes great pride in its stellar reputation and commitment to compliance. You’ve worked with regulators, auditors, and outside counsel for years to develop a sound compliance management system. Your outside counsel is a trusted friend who tells you what you need to hear, and who has assisted your company with especially difficult legal and policy issues.
Then out of the blue, you learn that an aggressive government agency has launched an investigation of your company’s collection practices and served a Civil Investigative Demand (CID), seeking extensive company records to be produced within a short period of time.
No company truly ever “wants” to be subject to a government investigation. But if you are the subject of an investigation, your company can take some comfort from its compliance work over the years, assuming it has established and maintained a “culture of compliance.”
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