Wednesday, March 9, 2011

SEC Update: Failure of "Tone at the Top" and General Counsel Conflicts

As if things couldn't get worse at the SEC, check out today's Washington Post link:
 
The SEC Chair amazingly relied on the former General Counsel himself and an "Agency Ethics Officer" (who is also an attorney in the General Counsel's office) to "sort out" the potential conflicts of interest involving the GC's inheritance of Madoff accounts from his mother's estate.  This could be a Harvard Business Review case study in exactly how an organization should NOT approach its corporate ethics responsibilities.  Tone at the top? None.  Separation of duties between the General Counsel and the Ethics Officer?  None.  Nurturing of an ethical culture at the SEC? Not quite.  This is definitely going to get ugly.  
 
Its time for other governmental regulatory agencies at the federal, state, and local levels to look themselves in the mirror, apply the horrendous case study of the SEC's failure to maintain the public trust, and conduct a self-assessment of their own ethics and integrity posture.

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