Corporate Compliance Essay
Part 1: Connecting Concepts (25 points, 800 words total)
Below are 4 pairs of concepts that we have studied. Explain how concepts in each pair are connected to each other and provide specific examples of how they may interact with each other. Respond to three of the pairs.
1. Auditors and Standards
2. Capture and Cooperative Enforcement
3. Privatized regulation and Gatekeepers
4. Whistleblowers and Culture of Compliance
Part 2: Short Answer (25 points, 800 words total)
Respond to two of the essay prompts below. Explain your answers with references to the reading.
1. What is the the board of directors’ role in compliance? What should it be?
2. Regulations often require that companies post the relevant legal requirements where employees can read them. For example, restroom often have signs reminding employees to wash their hands before returning to work; breakrooms often have signage detailing wage and hour laws. From the perspective of a regulator, what role do these requirements play?
3. From the perspective of front-line employees, are internal investigations different from investigations led by regulators, and if so how?
Part 3: Essay (50 points, 1500 words)
Answer one of the essay options below. Be creative.
Wells Fargo, one of the nation’s largest banks, has admitted to opening 3.5 million unauthorized accounts on behalf of its customers. Wells Fargo employees faced intense pressure to “cross-sell” customers new products and had mandatory sales goals to meet. The news of the unauthorized accounts came not from regulators but from an investigation conducted by the Los Angeles Times in 2013. Only after the Times broke the story did the L.A. city attorney launch an investigation. The city attorney sued Wells Fargo in 2015. Federal regulators did not bring charges until later. In late 2017, CFPB settled with Wells Fargo for a $100 million fine, although the CFPB may have been able to fine Wells Fargo $5,000 for each unauthorized account.
