Friday, March 8, 2013

Letter to BofA, Citigroup and Regions ethics & compliance

Sent: 3/7/2013 9:57:29 A.M. Central Standard Time
Subj: Bank wrongdoing; disabled ethics and compliance officers
Ms. Maria C. Hermida (via email
Chief Ethics Officer
Citi Ethics Office
1 Court Square, 24th floor
Long Island City, N.Y. 11101
Ms. Andrea Smith (via US mail)
Global Human Resources Executive
Bank of America
100 North Tryon Street
Charlotte, NC 28202
Mr. Hugh Nickson (via email
Ethics Program Manager
Regions Bank
1901 6th Avenue North
Birmingham AL 35203
Dear Ms. Hermida, Ms. Smith, and Mr. Nickson:
I am contacting you in your capacities as ethics and compliance contacts at your respective banks. The reason for contacting you is because your respective banks are currently involved in bank wrongdoing cases which are representative of a significant domain of corporate wrongdoing in which (i) seriously defective legal principles are invoked, (ii) there is undermining of your corporate ethics and compliance missions, (iii) ethics and compliance officers do not seem to have input in the domain, and (iv) there is otherwise inadequate representation of the societal interest in deterring corporate wrongdoing. (I have previously tried to contact Ms. Hermida but I don't know whether she saw my prior communication.)
As background, please be advised that I have been in communication with the Ethics & Compliance Officer Association, the Ethics Resource Center, and the Society of Corporate Compliance and Ethics, among others in the ethics and compliance field. You may see some of my communications here (SCCE), here (ERC) and here (ECOA).
The particular cases involving your respective banks are the pending securities class action lawsuits regarding Citigroup's CDO involvement, Bank of America's acquisition of Merrill Lynch, and the Region Bank's Morgan Keegan closed end funds litigation. I am filing objections in these class action cases, which allegations lay out the contentions I make in the first paragraph above. You may find my objections in the Citigroup and Bank of America cases here and my objection in the Morgan Keegan litigation here.
If you would like to engage in discussion with me about my contentions, I hope you will contact me.
Thank you.
Rob Shattuck
Birmingham, AL

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