Books and Records

Between SAC’s insider trading, the Obamacare snafus, NSA disclosures, and OTC glitches, one might think it’s hard to pick a winner in the year-end information governance sweepstakes.  But J.P. Morgan is in a class by itself, having paid billions for, among other things, the sub-prime mortgage crisis, hiring practices in China, and Bernie Madoff.

I guess its relationships with the government aren’t yet on the mend.  “J.P. Morgan Sues FDIC Over WaMu,” Wall Street Journal, December 18, 2013 C1 http://on.wsj.com/1cbBO5V

Apparently, in the scrambling to document the deal urged on it by the FDIC, J.P. Morgan didn’t clearly document who’d be responsible for claims attributable to WaMu’s pre-deal actions.  The documents fail to define “Books and Records.” I guess those terms need definition.  I also guess $18 billion in legal fees doesn’t cover definitions.

Do the deal documents you do under time pressure measure up to the task?  Is this an information governance point?  Does J.P. Morgan not sweat the small stuff?  Is there a culture?

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Filed under Business Case, Controls, Definition, Information, Internal controls, Legal, Operations, Risk, Use, Value

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