The Court of Appeals for the Second Circuit yesterday affirmed the dismissal of a securities class action alleging misrepresentations arising from generalized statements about an issuer’s compliance efforts and Code of Ethics. The decision in Singh v. Cigna Corporation held that such generic statements are not material because a reasonable investor could not have relied on them as representations of regulatory compliance. 

Recently confirmed Assistant Attorney General of the U.S. Department of Justice Criminal Division, Leslie Caldwell, has laid out her views as to what comprises the “hallmarks of good compliance programs.” In her new position, AAG Caldwell will repeatedly be in the position to decide whether corporate compliance programs are sufficient when making charging and settlement decisions and so her views on the subject are of particular import.