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Speed, smart speed, still wins in competition. Unfortunately, I find too many company executives are not heeding this reality when it comes to the changes in financial accounting for leases. Their outside accounting firms tell them something to the effect that this new proposed standard is going to take a while to finalize and make effective. This is the technical view, the compliance side. Finance and leasing company executives should pay attention to the market view.
Lessees are already receiving information about the proposed standard from the business media and their accounting firms. Again, this input will be on the technical side ' you must do this, and you cannot do that, and this is what you will look like, and so on. This kind of input causes alarm and may lead to push-back against leases and lease-like products. Some observers are already stating the self-fulfilling prophecy that there will be a reduction in leasing. That reduction may happen, and it certainly will happen unless finance and leasing company executives become proactive in the marketplace and do it now.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
Each stage of an attorney's career offers opportunities for a curriculum that addresses both the individual's and the firm's need to drive success.
A defendant in a patent infringement suit may, during discovery and prior to a <i>Markman</i> hearing, compel the plaintiff to produce claim charts, claim constructions, and element-by-element infringement analyses.