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When It Comes to Making Disclosure Decisions, Be Prepared

Joe Mont | June 12, 2012

Borrowing from the time-tested motto of Boy Scouts everywhere, companies need to “be prepared” as they approach potential questions from regulators and the perpetual debate over what to disclose, how to disclose it, and when.

Last week, at the Compliance Week 2012 annual conference, a panel tackled the tricky topic of disclosure and decisions that are often less about legal requirements than policy and judgment. Is self-disclosure the best way to stay ahead of a problem, or are there costly pitfalls that warrant a more measured, internal approach?

“This issue of what to disclose, when to disclose it, and how to get to the point where you can make an appropriate decision about it, particularly for those of us in heavily regulated industries, are decisions that are increasingly central to our job as compliance officers,” said Jay Cohen, chief compliance officer at Assurant.

“We have thousands of regulations that at any one time we could be violating,” he said of...

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