Epstein Secrets

imacy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corpo

cy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corporate Law, 26 REG. 26 (2003) (arguing that the Sarbanes-Oxley legislation was the most dramatic expansion of federal regulatory power). For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

imacy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corpo

cy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corporate Law, 26 REG. 26 (2003) (arguing that the Sarbanes-Oxley legislation was the most dramatic expansion of federal regulatory power). For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

PLIANCE HANDBOOK, supra note 317, at 111-23. 321 Stephen M. Cutler, Director, Division of Enforcement, SEC

8B2.1 & app. note 2 (2011). 311 This was underscored by then-SEC Commissioner Cynthia Glassman in 2003 ina speech on the SEC’s implementation of the Sarbanes-Oxley Act: “[T Jhe ultimate effectiveness of the new corporate governance rules will be determined by the ‘tone at the top. Adopting a code of ethics means