Friday, March 1, 2013

Is FSGO discipline a nullity?

From: RDShatt@aol.com
To: hpgoldfield@hoganlovells.com
Sent: 2/26/2013 12:41:29 P.M. Central Standard Time
Subj: Is discipline under FSGO Sec. 8B2.1(b)(6) a nullity?
Dear Mr. Goldfield,
I am contacting you in your capacity as a Board member of the Ethics Resource Center.
I am trying to establish whether or not there is any substance to "disciplinary measures" under FSGO Sec. 8B2.1(b)(6).
Thus far. I have not been able to elicit any contention by any ethics/compliance organization or professional that there is any meaningful implementation of practices and procedures for, and actual use of, "disciplinary measures" under Sec. 8B2.1(b)(6); and, based on inquiries I have made and the non-responses thereto, I have tentatively concluded that discipline under Sec. 8B2.1(b)(6) is, practically speaking, a nullity.
For an indication of the inquiries I have made, see these Comments for FSGO panel, these Emails to FSGO panel members, and the emails here related to the upcoming SCCE Government Compliance Conference.
I am sorry I cannot get much of a response from anyone on this, and I am possibly relegated to inferring, if no interested E&C organization or professional is willing to speak on this, that discipline under Sec. 8B2.1(b)(6) is, for all intents and purposes, a nullity.
I trust you can appreciate my effort to get information.
Thank you.
Sincerely,
Rob Shattuck

From: RDShatt@aol.com
To: Henry.Hart@shrm.org
Sent: 2/26/2013 12:44:46 P.M. Central Standard Time
Subj: Is discipline under FSGO Sec. 8B2.1(b)(6) a nullity?
Dear Mr. Hart,
I am contacting you in your capacity as a Board member of the Ethics Resource Center.
I am trying to establish whether or not there is any substance to "disciplinary measures" under FSGO Sec. 8B2.1(b)(6).
Thus far. I have not been able to elicit any contention by any ethics/compliance organization or professional that there is any meaningful implementation of practices and procedures for, and actual use of, "disciplinary measures" under Sec. 8B2.1(b)(6); and, based on inquiries I have made and the non-responses thereto, I have tentatively concluded that discipline under Sec. 8B2.1(b)(6) is, practically speaking, a nullity.
For an indication of the inquiries I have made, see these Comments for FSGO panel, these Emails to FSGO panel members, and the emails here related to the upcoming SCCE Government Compliance Conference.
I am sorry I cannot get much of a response from anyone on this, and I am possibly relegated to inferring, if no interested E&C organization or professional is willing to speak on this, that discipline under Sec. 8B2.1(b)(6) is, for all intents and purposes, a nullity.
I trust you can appreciate my effort to get information.
Thank you.
Sincerely,
Rob Shattuck

From: RDShatt@aol.com
To: glhinchman@f-a-f.org
Sent: 2/27/2013 8:12:51 A.M. Central Standard Time
Subj: Is discipline under FSGO Sec. 8B2.1(b)(6) a nullity?
Dear Ms. Hinchman,
I am contacting you in your capacity as a Board member of the Ethics Resource Center.
I am trying to establish whether or not there is any substance to "disciplinary measures" under FSGO Sec. 8B2.1(b)(6).
Thus far. I have not been able to elicit any contention by any ethics/compliance organization or professional that there is any meaningful implementation of practices and procedures for, and actual use of, "disciplinary measures" under Sec. 8B2.1(b)(6); and, based on inquiries I have made and the non-responses thereto, I have tentatively concluded that discipline under Sec. 8B2.1(b)(6) is, practically speaking, a nullity.
For an indication of the inquiries I have made, see these Comments for FSGO panel, these Emails to FSGO panel members, and the emails here related to the upcoming SCCE Government Compliance Conference.
I am sorry I cannot get much of a response from anyone on this, and I am possibly relegated to inferring, if no interested E&C organization or professional is willing to speak on this, that discipline under Sec. 8B2.1(b)(6) is, for all intents and purposes, a nullity.
I trust you can appreciate my effort to get information.
Thank you.
Sincerely,
Rob Shattuck

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