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We’re currently revising the paper in preparation for resubmission to : Government officials, advocacy groups, and the business press have raised concerns that former SEC employees may continue to have an influence on the SEC after leaving the agency.Using a hand-collected database of the characteristics of individual lawyers that represent firms in responding to SEC comment letters, we examine the impact of individual lawyers on the comment letter process.Estimates cited by the Wall Street Journal and other financial publications suggest more than 200 probes into options backdating are under way by the Securities and Exchange Commission, the Federal Bureau of Investigation and other regulatory and investigative units -- and that number is expected to grow.Backdating an option grant, of course, involves fixing the date of the option grant to an earlier point in time when the company's stock was lower, thereby creating an instant, or greater, spread between the "exercise" or "strike" price and the stock's market price.It all adds up to a loud wake-up call for HR executives, alerting them to the necessity not only of knowing when to sense a legal hazard, but to act proactively to prevent their organizations and executives from being wiped out by the next big wave, or even the last old one.The good news is that a set of relatively straightforward actions outlined below can be the "ounce of prevention" far outweighing the "pound of cure" after problems have started.Using network analysis, we document that backdating companies are more highly connected with other backdating companies via shared law firms.Further, logistic regressions indicate that the likelihood that a company backdates is 57 to 271 percent higher when its law firm has had another client that backdated.

In some cases, HR leaders have been alleged to be right in the thick of it.Meanwhile, the scope of investigations into the potential abuse of stock-options grants is expanding from the garden-variety undisclosed backdating, to "spring-loading" grants -- timing them to precede upcoming corporate "good news" presently known only to insiders to maximize their value.A recent high-profile spring-loading case involving Tyson Foods Inc.For starters, they point out that stock options are a key component of executive compensation, and this is the natural domain of HR.And, as a practical matter, they add, HR executives probably cannot avoid getting caught in the legal cross fire -- if not taking a bullet directly -- should things go awry, even if they weren't intimately involved: Their superiors will probably blame them, and subordinates will disavow them.

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4, Office of Community Oriented Policing Services, Washington, DC: August 2005. Carbon, Director, Office on Violence Against Women, January 6, 2012. METHODS FOR COUNTING HIGH-FREQUENCY REPEAT VICTIMIZATIONS IN THE NATIONAL CRIME VICTIMIZATION SURVEY, Janet L. Guidelines for Successful Researcher-Practitioner Partnerships in the Criminal Justice System, Findings from the Researcher-Practitioner Partnerships Study (RPPS), Tami P. TWO STEPS FORWARD, ONE STEP BACK – COMMUNITY ATTITUDES TO VIOLENCE AGAINST WOMEN: PROGRESS AND CHALLENGES IN CREATING SAFE AND HEALTHY ENVIRONMENTS FOR VICTORIAN WOMEN, Natalie Taylor and Jenny Mouzos, Australian Institute of Criminology and Victorian Health Promotion Foundation, Canberra, AU: 2006. Department of Justice, Washington, DC: January 2003.

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