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Directors & Officers Liability Exposures Course Outline
Chapter 1 Introduction and Overview
Chapter 2 The Corporation and the Functions of Directors & Officers
What is a Corporation?
The Defining Feature of a Corporation
Chartering of Corporations
Public versus Private Corporations
The Functions of Directors and Officers
Specific Functions of Corporate Directors
Inside versus Outside Directors
Board Committees
Chapter 3 Common Law Duties of Directors & Officers
The Four Fiduciary Duties
The Duty of Loyalty
The Duty of Obedience
The Duty of Due Care (also Known as The Duty of “Due Diligence”)
The Duty of Good Faith: An Emerging Fiduciary Duty
Chapter 4 Federal Securities Liability
The Securities Act of 1933
Liability under Section 5: the Obligation To Register a New Security
Liability under Section 11: the Obligation To Make Truthful Statements about Securities
The Securities Exchange Act of 1934
Liability under Section 10(b): the Prohibition against Deceptive Acts/Statements
Liability under Section 10b-5: The Prohibition against "Insider Trading"
The Sarbanes-Oxley Act of 2002
Chapter 5 Liability under Other Types of Statutes
Liability for Anticompetitive and Unfair Business Practices
Predatory Price-Cutting Activities
Disclosure of Trade Secrets
Liability for Copyright/Patent/Trademark Infringement
Copyright/Patent Infringement
Trademark Infringement
Liability for Racketeering Activities
Treble Damage Provisions
Liability for Mismanagement of Investment Company Funds
Liability for Mismanagement of Employee Benefit Plans
Liability for Failure To Collect and Remit Payroll Taxes
Liability for Political Contributions
Liability for Safety Violations
Environmental Liability
The Comprehensive Environmental Response Compensation and Liability Act
The Resource Conservation and Recovery Act
Liability in Connection with Government Contracts
Liability in Connection with Bribery of Foreign Officials
Liability in Connection with Employment Laws
Coverage under Stand-Alone Policies
Chapter 6 Primary Defenses to Corporate Liability
The Importance of Minutes at Board Meetings
The Business Judgment Rule
The Essence of the Business Judgment Rule
The Business Judgment Rule: A Case Study
Dissent
Ratification
Chapter 7 Securities Class Action Claims
What are Securities Class Action Claims?
Advantages of Class Action for Plaintiffs
What Triggers a Securities Class Action Claim?
Securities Class Action Claims: A Typical Scenario
What Specific Actions Give Rise to Securities Class Action Claims?
The Private Securities Litigation Reform Act: Reducing Class Action Abuses
Anatomy of a “Shake-Down”: How Many Class Action Lawsuits Originated
Specific PSLRA Reforms
The Class Action Fairness Act of 2005: Another Attempt To Control Class Actions
Goals of the Act
Basic Provisions
Impact
Securities Class Action Claim Data
The Correlation between Claim Filings and Industry Sector
Historical Class Action Claim Filing Data
Chapter 8 Specific Situations Giving Rise to Securities Class Action Claims: Part 1
Financial Restatement Claims
Notable Financial Restatement Claims
IPO-Related Claims
How Does an IPO Work?
Types of IPO Claims
Claims from “Change-of-Control” Situations
The Typical Change-of-Control Claim Scenario
Frequent Claimants
Types of Claims Made against Directors and Officers in Change-of-Control Situations
Resistance to Hostile Takeovers
Approval of Friendly Takeovers
Preacquisition Mismanagement
Failure To Disclose
Mismanagement (Following the Acquisition)
Claims from “Options Backdating”
What are “Stock Options”?
What is “Backdating”?
Chapter 9 Specific Situations Giving Rise to Securities Class Action Claims: Part 2
Claims from Auction Rate Securities
What are Auction Rate Securities?
What Went Wrong?
What Were the Consequences of Failed Actions?
What Is the Basis of the Lawsuits?
Claim Counts
Claims from the Subprime Mortgage Lending/Credit Crisis
Step One: Subprime Loans
Step Two: Securitization
Step Three: Credit Derivatives
What Are the Leading Claim Allegations against Corporate Directors and Officers?
Investor Lawsuits
Shareholder Lawsuits
Claims from the Bernard Madoff Investment Ponzi Scheme
The Scheme, in Brief
The Reality
The Unraveling
What Are the Leading Claim Allegations against Corporate Directors and Officers?
Claims from Private Equity Operations
What is a Private Equity Group?
How Do Claims from Private Equity Deals Arise?
Chapter 10 Parallel Proceedings
Derivative Claims
Common Breaches of Duty Alleged in Derivative Claims
A Notable Derivative Claim
Opt-Out Lawsuits
Why “Opt-Out”?
ERISA “Stock Drop” Litigation
401(k) Monies Invested in Company Stock: The Trigger for ERISA Stock Drop Litigation
Specific Allegations against Directors and Officers in ERISA Stock Drop Cases
Securities Class Action Litigation versus ERISA Stock Drop Litigation
Regulatory and Criminal Proceedings
Regulatory Investigations and Class Action Claims
Criminal Prosecutions and Class Action Claims
Special Issues Associated with Parallel Proceedings
Defense Coverage Issues: The Shrinking Limits Problem
Chapter 11 Underwriting Directors & Officers Liability Insurance: Part 1
Underwriting Data
Annual Report
Proxy Material
Corporate Bylaws
Roster of Directors and Officers
Dun and Bradstreet Report
SEC Reports
Financial Situation
Profitability
Leverage
Accounting and Financial Reporting Practices
Liquidity
Stock Price Volatility
Industry/Competitive Position
Market Share
Competitive Structure of the Industry
Revenue Sources
Industry Group
Chapter 12 Underwriting Directors & Officers Liability Insurance: Part 2
Internal Company Factors
Merger and Acquisition Activity
Breadth/Concentration of Stock Ownership
Future, Company-Specific Risks
Public Offerings and Repurchases
Service Provider Relationships
Company Size
Company Age
Degree of Diversification
Degree of Centralization
Public Perception
Risk Management Program
Loss History
Composition and Operation of the Board of Directors
Degree of Control by the Chairman
Board Selection Criteria and Composition
Compensation Method of Management
Analyzing Board Turnover
Assessing the Board’s Knowledge of the Organization
Conducting Face-to-Face Meetings with Management
Conclusion: The Art of D&O Underwriting
Chapter 13 Controlling Directors & Officers Liability Claims Part 1: General Suggestions
Encourage Active Questioning and Appropriate Dissent
The Problem with Board Appointments: Most Often a Function of Friendship
Consult with Legal Counsel and Outside Experts
Maintain Contact with Operating Managers
“Management by Walking Around”
Avoid Embarrassing Corporate Actions
Require Review of the D&O Policy and Application
The Importance of the Application
Monitor Insider Trading
Investigate Warning Signs
Enron: A Case Study in Financial Manipulation
Don’t Manage to Artificial Indictors
Chapter 14 Controlling Directors & Officers Liability Claims Part 2: Effective Corporate Governance
What Is “Corporate Governance”?
Assure Independent Decision Making on the Board
Limit Corporate Boards to No More than Three Insiders
Assign Only Independent, Outside Directors to the Three Key Committees
Set Mandatory Term Limits
Ban (or at Least Limit) Stock Sales by Directors, for the Duration of Their Service
Require a Minimum Level of Stock Ownership
Reform Option-Related Compensation Practices
Accounting Rules Incentivize Option Grant Abuses
Specific Option-Related “Best Practices”
Separate the Roles of Board Chairman and CEO
Split of Board Chairman and CEO Roles Common in Canada and the U.K.
Better Monitoring of CEO Performance
Board Chairman and CEO: Too Demanding for One Person?
Appoint an Independent Lead Director: An Alternative To Splitting the Roles
Conduct “CEO-Free” Board Meetings
Facilitating Frank Discussions
Periodically Evaluate Director Performance
Areas To Evaluate
Improve Audit Committee Effectiveness
Provide Directors with Relevant and Timely Information
Create an Adequate Support Structure
Limit Time Devoted to Board Service
Semi-Retired Directors versus Directors with Full-Time Jobs
Limiting Board Service is a Growing Trend
Avoid Conflicts of Interest
Conflicts of Interest: An Example
“Side Deals”: A Frequent Source of Conflicts
Eliminate Corporate Board “Interlock”
Board Interlock: Potential for Quid Pro Quo Deals
© 2000-2012 International Risk Management Institute, Inc. (IRMI). All rights reserved.
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