James P. McLoughlin, Jr., Neil T. Bloomfield, and Frank E. Schall issued a Client Advisory titled "Timely Disclosure of Investigation Loss Contingencies: The SEC’s Aggressive Enforcement Stance." The Advisory discusses SEC v. RPM International, Inc., No. 16-01803 (D.D.C. filed Sept. 9, 2016), in which the SEC has pushed its aggressive litigation strategy in pursuit of its policy of compelling registrants to accelerate loss contingency disclosures. The SEC filed against RPM International, Inc. and its general counsel, Edward Moore, alleging the failure to disclose a material loss contingency and record an accrual as a result of the filing of a qui tam complaint against RPM and a subsidiary and a resulting Department of Justice investigation. RPM International doubles down on the SEC’s effort to require earlier disclosures of loss contingencies based upon internal evaluations without waiting for the classic internal triggers of a government demand or notice of a pending action by the government. Click to read the full Client Advisory.
Frank has extensive experience conducting internal investigations for clients in the United States and abroad pertaining to a wide range of issues. He strives to develop creative solutions and strategic approaches when ...
Jim has dedicated his career to winning civil and criminal cases. He has prosecuted and defended dozens of appeals. Jim advocates for clients in regulatory and criminal investigations and cases conducted by the Department of ...
Neil regularly represents clients with responses to inquiries by Federal (e.g. CFTC, DOJ, OCC, FRB, SEC, IRS, and various U.S. Attorney's offices), State (e.g. the North Carolina Attorney General and other state Attorneys ...
About MVA White Collar Defense, Investigations, and Regulatory Advice Blog
As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies face challenging regulatory and criminal enforcement dynamics. We help keep our clients up to date in these fast-moving areas and to serve as a thought leader.
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