Regulation and Compliance
Compliance Assignment
In your responses, rely upon and refer to the course reading materials, class lectures, and class notes, as applicable. Do not conduct any outside research or consult any resources other than those discussed in the course or included in the syllabus. Your responses should be in Times New Roman 12-point font, double-spaced, with page numbers. Citations do not need to take any particular style or format; however, they should be placed in footnotes. There are no required page minimum or maximum lengths. Page approximations are provided as a point of reference only.
I. Demonstrates Content Knowledge
- Identifies and explains key regulatory and compliance considerations
- Creates analytical framework to address the identified issues
- Recognizes any nuances or complexities and thoughtfully addresses them
- Reaches conclusions while recognizing aspects that are open or unresolved
- Identifies pertinent follow-up questions and/or recommendations
II. Demonstrates Analytical and Writing Skills
- Writing is clear, concise, organized, and easy to understand
- Response has a clear introduction and a thoughtful conclusion
- Analysis is logically developed and presented
- Response is free of grammar and usage errors
- Response follows requested format
H. Granger is the newly appointed chief compliance officer of a large US for-profit, private corporation called Wizard World Corporation (referred to as “Wiz Corp”).
Facts (Part 1): After two stressful months on the job, Ms. Granger has realized that
Wiz Corp is “way behind the curve on compliance.” While the Compliance Program appears to be sophisticated on the surface, most employees do not seem to know much about it, and there isn’t a Code of Conduct. Even the Wiz Corp’s executives seem clueless about the importance of compliance and have jokingly made comments about how best to “get around” compliance policies. Ms. Granger further realizes that notwithstanding all the promises she was made when she interviewed for the job, she is not able to access many resources. She is stuck in a basement office in a mostly empty building on the edge of Wiz Corp’s campus, and she never interacts with the board of directors. She doesn’t have a sense of how Wiz Corp is doing on compliance since there is no hotline or means for employees to flag compliance concerns. She is so busy “putting out fires” that she never has time to make any real progress on any of her compliance program goals, especially since she has not been allowed to hire anyone to assist her.
Answer the following questions, but do not draft a compliance program or any policies.
(approximately 3 pages)
- (a) Do you believe that Wiz Corp must redesign and update its Compliance Program to make it effective? Why or why not? How should Ms. Granger begin?
- (b) What guidance should she consult? Would your answer differ if Wiz Corp were a publicly traded corporation?
- (c) What actions should she take, and what types of policies should she implement to improve the effectiveness of Wiz Corp’s Compliance Program?
Facts (Part 2): Another few months have passed, and Ms. Granger has realized that Wiz Corp’s board of directors is very disconnected from the compliance function. The chief executive officer, H. Potter, has asked you (an outside board consultant) to prepare a brief report for the next board of director’s meeting. Mr. Potter has asked you to summarize the board’s fiduciary duties and explain what role you believe the board should play in compliance and the reasons why. He would also like you to explain how you believe the board and the compliance function should interact. Your report should take the format of a memorandum addressed to the board using the format provided here. (approximately 2–3 pages)
To: Board of Directors
From: [Your name], Board Consultant
Date: [Date of report submission]
Facts (Part 3): Ms. Granger is now approaching her one-year anniversary as Wiz Corp’s chief compliance officer. It has been a busy year, but she believes that she has made some progress. The aspect that continues to worry her is the rocky relationship between Wiz
Corp’s compliance department and the legal department. Wiz Corp’s general counsel, D. Malfoy, resents Granger because the compliance function was within the legal department before she was hired, and he believes it should continue to be under his domain. Furthermore, the compliance department recently conducted an internal investigation (under Ms. Granger’s supervision) due to some compliance irregularities that an employee brought to her attention relating to a contract with an important vendor, Azkaban, Inc. The legal department refused to assist with the investigation notwithstanding Ms. Granger’s repeated requests. (Ms. Granger has heard that Malfoy is very good friends with the owner of Azkaban, Inc. and that Malfoy helped Azkaban secure the contract with Wiz Corp in the first place.) The investigation has revealed significant compliance concerns, and Ms. Granger isn’t sure how to proceed. Further, the employee who initially raised the compliance issue, R. Weasley, is being given the “cold shoulder” around his department ever since he filed the complaint.
Answer the following questions, but do not draft a compliance program or any policies.
(approximately 3 pages)
- (a)What compliance concerns do these facts raise?
- (b)What do you recommend Ms. Granger do to address these concerns?
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