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Ethics Framework™, a patent-pending process for Ethical and
Effective Corporate Governance

Ethics Ratings 1 and 2   Ethics Ratings 3, 4 and 5
 

Empower members to achieve

Effective and Ethical Corporate Governance

Empower members to solve

Ineffective Corporate Governance
including delisting and restatement risk
Management
Management
Ethics Ratings 1 and 2 Ethics Ratings 3, 4 and 5
Code of Ethics, 17 §229.406 Illegal Acts Per Section 10A
Compliance with laws and regulations Compliance violations
Safe and Sound Practices (FDICIA) Unsafe, Unsound: CAMELS Ratings 3, 4 and 5
Well Managed Troubled Condition: CAMELS Ratings 4 and 5
Self-Insuring Poor Management: CAMELS Ratings 4 and 5
CAMELS Ratings 1 and 2 Federal Bailout

Moral Hazard
Internal controls over financial reporting Violations of internal controls over financial reporting
 
Corporate Governance
 
Corporate Governance
Ethics Ratings 1 and 2 Ethics Ratings 3, 4 and 5
Effective and Ethical Corporate Governance

 Corporate Governance Listing Standards
 Ineffective Corporate Governance
 Delisting and Restatement Risks due to
  Violations of Exchange Listing Standards:
 Code of Ethics, 17 §229.406   Code of Ethics, 17 §229.406
 Compliance with laws and regulations   Illegal Acts Per Section 10A
 Effective oversight of internal controls over
 financial reporting		   Violations of internal controls over financial reporting
 Effective Oversight of Auditor   Audit Risks

  Material Weakness: Audit Standard No 5.
 Compensation   Compensation
    Proxy on Ineffective Corporate Governance per the
     SEC’s Staff Legal Bulletin No. 14E (CF)
 
Audit Risks
  
Audit Risks
Ethics Ratings 1 and 2 Ethics Ratings 3, 4 and 5

Internal controls over financial reporting (ICFR)
Audit Risks
 GAAP, ICFR do not encompass illegal acts
 Illegal Acts Per Section 10A
 Covenant violations are a material misstatement
 Material Misstatements
 Material Weaknesss
 Fraudulent Statement
 Restatements

Claw back of compensation
Investment Advisers
Investment Advisers
Ethics Ratings 1 and 2 Ethics Ratings 3, 4 and 5
Investment Strategy Risk Profile Investment Strategy Risk Profile
Code of Ethics, 17 §275.204A-1  Delisting Risk of Securities
 Compliance with securities laws
  Restatement Risks
  Antifraud Rule (Rule 206(4)-8) Prohibition of Fraud by Advisers
  Special Risk Assessments: Moral Hazard
   Systemic Resolution Fund per the
   Financial Stability Improvement Act of 2009.
  Proxy on Ineffective Corporate Governance per the
   SEC’s Staff Legal Bulletin No. 14E (CF)
 
Restatement Risks
  
Restatement Risks
Ethics Ratings 1 and 2 Ethics Ratings 3, 4 and 5

Restatement Risks

  • Impact Earnings
  • Capital
  • Compensation
  • Enterprise Values

Restatement Risks

  • Impact Earnings
  • Capital
  • Compensation
  • Enterprise Values
Products and Services
Products and Services
Ethics Ratings 1 and 2 Ethics Ratings 3, 4 and 5
Financial Holding Companies Financial Holding Companies
Auditors Auditors
Regulators and Exchanges Regulators and Exchanges
   
Ethics Ratings Research Reports
 Ethics Ratings Research Reports
Investment Advisers Exposure Report Notification of Regulatory Breaches
    Investment Advisers Exposure Report