John A. Nathanson and Jason M. Swergold Shearman & Sterling write: It has been three and a half years since the SEC announced that it would begin using several types of cooperation agreements to resolve investigations under the then-newly implemented Cooperation Initiative. Since that time, information about these agreements has been scarce, and for those facing the critical decision of whether or not to cooperate, many important questions persist.
SEC's Cooperation Initiative: Should You Go Along to Get Along?
New York Law Journal
September 18, 2013