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Sometimes it seems like you can't win. Law firms spent the better part of two decades effectively extricating themselves from unaffordable, life-threatening unfunded retirement packages during a period of constantly growing business, only to find they have few if any financial mechanisms available to incent retiring partners to actually transition their clients to the next generation, prior to retirement. Not that most firms were particularly good at linking unfunded deferred compensation to transition, but in theory, at least, you could. But now, at a time when it appears a permanent buyers' market has set in and the market is growing slowly if at all, retaining clients through partner transition is ever more critical. And most firms are woefully short of actual tools to encourage such transition.
Pay Lip Service to Transition Today '
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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.
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