Welcome back to the podcast, Bride, Swindler Steel. I'm Alexander Rogge, and today we have a comprehensive review of self-reporting and cooperation, including new incentives and expectations.

Our guest is John Davis, a member with Miller and Chevalier, who spoke at the recent

Trace Forum in Annapolis. Here's John. I want to go very quickly through the current policies

that are out there with regard to self-disclosure cooperation and some of the agency's

expectations related to those policies. And then we're going to talk about. The second part, some key issues of consideration, including some illustrations from recent

cases, as well as some things that the policies don't cover that you as a company need to

think about when you're thinking about self-disclosure and cooperation.

One thing you will note, as we go through this, is almost all these policies are DOJ focused.

Lots of shiny new stuff that DOJ has done them within the last year, as many of you already know.

The SEC does have its baseline policies on these, which have existed for a very long time,

and we've seen in the various recent orders.

I don't want to suggest that it's only DOJ

that's been active in this area,

but they're the ones who are announcing new things

and revising some of the positions they've taken over time.

I also should say, by the way,

Dental Council will thank me for this,

that I personally am not Disclosure Council,

though I operate and talk to Disclosure Council

in investigations all the time,

but if you have a disclosure issue,

you want to talk, you want to think about it.

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