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On Dec. 17, 2012, the Equal Employment Opportunity Commission (EEOC) approved its Strategic Enforcement Plan (SEP). The purpose of the SEP, according to the Commission, is “to focus and coordinate the EEOC's programs” by adopting “national priorities”; the EEOC believes identifying these priorities is essential in making the best use of its limited resources, and has indicated that it will apply the full range of “integrated enforcement” strategies in addressing these areas. In its SEP, the EEOC identified six “national priority” areas. Through what it calls a “targeted approach,” the EEOC has indicated that charges of discrimination involving one or more of these priority areas will receive “first and highest priority” and “a greater share of agency time and resources.” For General Counsel looking for a cost-effective way to reduce risk and to stay off the EEOC's radar, knowing what the EEOC's national priorities are and conducting a self-audit in these six areas is a good start.
Strategic Enforcement Plan Priorities
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The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
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