Defending Against Class Action Suits In The World Of Sarbox

In April of 1998 Cendant disclosed a restatement ofinterests of shareholders - but rather in what I'd call
1997 results, including a reduction in net income of $ 100'boardroom atmosphere.' Board membership requests
million due to various accounting irregularities. Then onare being declined in record numbers due to the
July 14, 1998 Cendant announced a furtherperception of risk of being a director in this
restatement of financial results for 1995, 1996 and 1997,environment. However, corporate governance
including all quarters due to recognition of fictitiousprovisions are being taken much more seriously and
revenues and cookie cutter reserve mismanagement.since Sarbanes-Oxley mandates them, these recent
At the end of August Cendant filed an SEC reportrevelations almost guarantee its place in history.
indicating a reduction in operating income of $ 500BACKDATING STOCK OPTIONS: CORPORATE
million; a reduction in net income before taxes of $ 297REMEDIATION
million and the effect on earnings per share. As aAs of August 17th the Wall Street Journal posted a
result, the market price of the stock decreased from astudy of 87 companies that have initiated probes,
high of $35. in April to $11. per share in August. Normallyannounced restatements, had executive resignations
a 10% drop in stock price following an adverseor Department of Justice inquiries into their stock
announcement is enough to trigger a class action suitoptions practices. The SEC has filed civil charges
within 72 hours. Here the drop was precipitous: 69%.against executives of public companies, alleging that
Fifty lawsuits were filed in the U.S. District Court whichthey engaged in a decade-long fraudulent scheme to
were consolidated by the judge with severalgrant undisclosed, in-the-money options to themselves
institutional investors as the Lead Plaintiffs. Hundreds ofand to others by backdating stock option grants to
thousands of documents were produced by Cendant,coincide with historically low closing prices of their
Ernst & Young and the various defendants. Anstock. These complaints have alleged that former
investment banking firm and a forensic team wereexecutives collectively realized millions of dollars of
retained as expert witnesses. Cendant settled for $2.8ill-gotten compensation through the exercise of illegally
Billion. Ernst & Young settled for $ 335 Million. Thisbackdated option grants and the subsequent sale of
settlement was followed by even larger valuations inrelated common stock.
the cases of WorldCom ($ 6.2 Billion) and Enron ($ 7.1In a separate matter, U.S. Attorney's Offices have
Billion, pending final court approvals).unsealed criminal complaints charging executives with
Enron directors agreed to settle class action againstconspiracy to violate the antifraud provisions of the
them for $ 168 million as their proportionate share offederal securities laws, wire fraud and mail fraud. It has
the settlement. Insurance covered most of the cost,been alleged that backdated option grants and secret
but left them with terms that required the directors tooption slush funds were "deceits of the highest order"
personally pay $ 13 Million. WorldCom directors had aupon shareholders. Executives, according to the SEC,
settlement requiring them to pay their proportionatehave repeatedly used hindsight to select dates when
share, $ 54 Million, leaving them $ 18 million owed on athe closing price of their common stock was at or
personal liability basis. The directors in the settlementnear a quarterly or annual low. The complaints further
admitted no wrongdoing.allege that under well-settled accounting principles, in
Backdating Stock Optionseffect at the time, companies that granted
The backdating scandal we are currently readingin-the-money options were required to record a
about in the Wall Street Journal may, according tocorresponding compensation expense and disclose
academics, affect up to 3,000 publicly-held companies.such amounts in filings with the Commission. The
Defense attorneys, plaintiff attorneys and expertexecutives have also been charged with violations of
witness are beginning to mobilize. This potentiallythe Sarbanes-Oxley officer certification provisions of
massive arena of litigation and expert testimony hasthe federal securities laws. Injunctive relief, civil
occurred because of the practice in the last ten yearspenalties, disgorgement, with prejudgment interest, and
of publicly-held companies granting stock options toofficer and director bars against each of the
key executives which were in-the-money but notdefendants has been requested.
properly recorded as compensation expense, thusHOW THE BACKDATING OCCURRED
violating GAAP, and misstating tax liabilities as wellIt is helpful to review how the practices originated in
over every quarter since the practice began. In otherorder that remediation of one's own internal control
words, dates were assigned to the options usingpolicies can effectively take place. The executives
hindsight that were earlier dates than the actual grantdirected and controlled the option grant process and
date. The SEC has just begun an investigation intoinitiated the backdating schemes. Among other things,
approximately eighty companies, and the list isthey specifically selected the backdated grant dates
expanding daily. The DOJ and U.S. Attorney officesby interfacing with the Compensation Committee.
are making logistic decisions as to how to allocateGrant documents with false grant dates were
predicted case load. Several criminal charges haveapproved by the Compensation Committee.
been filed. At a minimum, companies that are involvedUnscheduled grants were the modus operandi. A
will face civil charges by the SEC, massivespreadsheet contained lists of proposed grantees. At
restatements and therefore the virtual guarantee ofsome point, the executives "cherry-picked" the grant
class action and derivative suits. The suits have asdate by looking back at their historical stock prices and,
their basis that the companies in question and their topwith the benefit of hindsight, chose a grant date that
executives as well as boards of directors havecorresponded to a date on which the common stock
engaged in breaches of fiduciary duty, grosswas trading at a relative low. The master list was then
mismanagement, unjust enrichment and violations ofsubmitted to the Compensation Committee for
the SEC Act of 1934. Back-dated options haveapproval.
allowed the defendants to reap millions of dollars inUnanimous written consent forms pertaining to the
unlawful windfall profits at the expense of theproposed grant were sent to Compensation
company. One law firm alone recently filed 34Committee members for signature. It was known
derivative suits. It's the largest area of civil litigation inamong the executives that these dates were the
history that is beginning to unfold before our very eyes."low-ball" look-back dates they had previously chosen.
Shareholder Derivative SuitsCompensation Committee members were generally
Shareholder derivative suits are increasingly filed innot aware of an impending grant prior to receiving the
connection with class action suits. A primary concern ismaster list. The Committee members then signed, but
that directors and officers will find themselves withoutdid not date their copies of the consents and returned
coverage for defense costs, awards for plaintiff'sthem. Based upon their involvement in the option grant
attorneys fees and a monetary settlement. Directorprocess, each of the defendants knew, or were
& Officer insurance policies sometimes excludereckless in not knowing, that the unanimous written
payments for non-civil litigation, as where certain typesconsents were false because the "as of" dates that
of fraud which involve scienter exist. Even if it does,were inserted into the consents and reflected in the
usually the coverage does not begin until an indictmentcompany's books and records did not represent the
is brought. Another area that contains elements of periltrue grant dates.
is that often payments are made on a first-come,The executives knew that no corporate action to
first-serve basis. In other words, in the order that claimsapprove the options grants had actually occurred on
are filed. This can often lead to a shortage in the casethe "as of" date. They knew this because they were
of a settlement.the ones who had picked the grant dates by use of
There is an upward trend in filings of derivative suits,the look-back tables, with the benefit of hindsight. They
which are filed primarily in state courts, as opposed tohad examined historical trading prices and selected a
class action suits, filed in federal district courts. Statedate with a low trading price. Options with backdated
courts often permit plaintiffs to recover ondates in effect also accelerated the vesting schedule
non-unanimous verdicts (required in the federalbecause the Company used the backdated date for
system) and some state laws permit lower standardsvesting purposes, not the date of the actual
of findings for recovery purposes. These stand-aloneCompensation Committee approval. A large number of
derivative suits are normally for breach of fiduciarygrants were grants at or near the lowest price for the
duty, proxy violations, excessive compensation andfiscal quarter or year. In an article published by the Wall
breach of the duty of care or duty of loyalty.Street Journal, the patterns of stock options grants
The Business Judgment Rule supports active decisionswere analyzed and astronomically high odds, some
of the Board of Directors, but it does not cover theseapproaching one is six billion, were determined to exist
breaches. For example, breach of the duty of carethat such grants would have fallen on dates just
does not cover unintelligent decisions, ill-advised actions,ahead of sharp gains in the related corporate stock
or illegal breach of federal laws. Failure to questionprice by chance.
management representations is another example ofThe secret backdating schemes allowed the
this type of breach.defendants to disguise the fact that the Company
One solution to adequate D & O coverage is awas paying higher compensation to executives and
Side A-only policy, which can protect directors andemployees by awarding them in-the-money options,
officers from losses not normally indemnified. Theseand to avoid having to expense the in-the-money
policies typically provide coverage even under adverseoptions as compensation expense, thus avoiding
conditions, including corporate bankruptcy, when thereductions to the company's net income and EPS. In
limits of the traditional policy have been exhausted andaddition, certain large institutional investors have long
under cases where the normal policy excludesbeen opposed to stock option plans that allowed
payments. Some states do not permit corporategrants of options at below the fair market value of the
indemnification of unsuccessful defense againstunderlying stock at the time of the grant. This is the
derivative suits and in these cases as well a Sidebasis for the tens of billions of dollars of derivative suits
A-only policy will provide coverage.filed in recent weeks against related corporations by
The Private Securities Litigation Reform Act of 1995law firms on behalf of large institutional investors.
provided modifications and a safe harbor forThe California Public Employees' Retirement System
corporations in one aspect of derivative suits - the(CalPERS) is the largest U.S. public pension fund, with
forward-looking statement. Tenuous inferences are notover $ 200 Billion in total assets. They have recently
permitted in plaintiff pleadings. Allegations must includewritten an open letter to the Chairs of the
specificity as to falseness or why the statementsCompensation Committees of a number of portfolio
made by the company were misleading. Under thecompanies related to inquiries on employee stock
safe harbor provisions of the Reform Act, a companyoption backdating practices. Their letter contains
is not liable for projections which are inaccurate if suchimplications of allegations, including lack of oversight by
statements are properly identified and accompaniedthe Board of Directors, weak internal controls, weak
by a cautionary statement which indicates that actualinternal and external audit practices, poor accounting,
results could differ from projected results, and liabilitysignificant income tax consequences for persons
also does not exist if the plaintiff does not prove theimplicated for backdating options, and problems with
forward-looking statement was made with knowledgethe Executive Compensation Plan Administrator.
that it was misleading. Forward-looking statements areSenator Chuck Grassley of Iowa, Chairman of the U.S.
often made verbally at analyst conferences, so thisSenate Committee on Finance, has publicly stated: "It's
provides some measure of assurance to theone thing for an executive to make big profits
corporate public relations department. However, asbecause he's improved his company, but it's a whole
regards the option backdating practice, there is nodifferent thing to make big profits because he's playing
safe harbor.fast and loose with the dating of stock options. Outside
Trading Modelsthe corporate suite, Americans don't get to pick and
The economic basis of these settlements is an areachoose their dream stock price. The market dictates
of adversarial tests. In a monograph in the early 1990s,the price."
several authors criticized the use of trading models toThe CFA Institute recently published an open letter to
estimate aggregate damages in class action suits,the SEC stating "In the case of Post-Dating, senior
claiming that the results were not reliable and oftenexecutives (and possibly directors) used inside
overstated damages by as much as 74%. Daubertinformation or post-closing market prices to determine
grounds have been challenged on a variety ofwhen to retroactively set the effective date of
proposed models. In Daubert the Supreme Courtshare-based awards in order to enhance the return of
directed federal courts to consider four factors insuch awards. This practice also appears to have
evaluating expert testimony under Federal Rule ofinvolved falsified accounting, may circumvent financial
Evidence 702: (1) the general acceptance of thereporting requirements for 'variable' option grants, may
economic model; (2) potential rate of precision error; (3)conflict with governance requirements related to the
peer review or publication; (4) whether the theory haspricing of stock options, and may ultimately lead to
been tested. In finding that various proposed tradingcriminal and tax penalties against companies engaged
models do not meet these standards, the court isin these activities, thereby harming shareowner value
concerned about whether the model has been testedeven more."
and whether the model has been accepted byREMEDIATION
professional economists.In the real world, the best stance is one of pro-active
The Journal of Legal Economics is a good startingremediation before any investigation by third parties
point for obtaining solid valuation models. It is a doublebegins. Materiality thresholds need to be considered
blind refereed journal. Each manuscript is reviewed byaccording to SEC Bulletin No. 99 and Sarbanes-Oxley
at least three qualified individuals, in addition to thethresholds. If the materiality threshold is not breached,
Editor. It was conceived as a forum for contributingthen no restatements will occur. If a restatement
authors, both from the profession of lawyers as welloccurs, it almost guarantees an SEC investigation and
as the quantitative professions of accounting,also a finding of a "Material Weakness" by one's
economics and finance, to offer constructive insightsthird-party auditors. Material Weakness findings can
to colleagues. It is designed to be a useful researchcause the loss of significant blocks of market
tool for application as well as theory.capitalization upon disclosure.
In theory, the "out-of-pocket" loss is the measure ofThe problems are not restricted to Information
damages in open-market class suits. Therefore aTechnology companies. Their excess returns in the
defrauded buyer can recover his share of classstudies performed by the academics at the University
member's damages, less applicable attorney fees,of Iowa and others were what caught initial attention
which can range from 15-30%. However, since thisto the issue, but the scope is beyond IT companies. It is
actual trading data is buried in repositories, modelsestimated that close to 3,000 companies are involved.
have been chosen to produce tangible results. TheIn many of these cases undoubtedly management has
Private Securities Litigation Reform Act of 1995 leavesretained its integrity, and the element of scienter does
it open for the court to select the most reliable methodnot exist. The rest of the public companies need to
of damages proof that is available. Two-trader modelsstudy and research adequate Sarbanes procedures to
also exist, which assume, probably correctly, that thereassure they are not affected in the future. The initial
are passive investors and there are traders. Tradersstudies of proxy statements for statistics on options
of course have a higher probability of acquiring andbefore the implementation of Sarbanes Oxley
selling shares, and thus this model utilizes parameterschanged the reporting requirements to 2 trading days
for damage estimates with the damages estimatedfollowing August of 2002 indicated the problem existed
using depository record data. One-trader models oftenas early as 1996 with the majority of companies. Grant
significantly overstate damages by 90-98%.patterns on excess return post-option pricing began
Assumptions can therefore lead to bias. Three-traderlargely in the mid-1990s. One company alone has close
models also exist which involve high-activity investors,to two million documents that need to be examined to
low-activity investors and intraday-traders (who do notdetermine the extent of the backdating issues. I
utilize overnight positions). Often these traders canunderstand investigative, forensic and related
account for up to one-third of all trading activity.professional costs in this one case alone are targeted
Recommendationsand budgeted for $70 Million dollars. This does not
One strategy that is sometimes effective is theinclude defense or settlement costs for related
formation of a special litigation committee (SLC) thatclass-action and derivative lawsuits.
has the substance and form of independence. TheWithout going into specific detail what is referred to as
committee has the responsibility of retaining forensicthe Tone at the Top must be re-established at
teams to review thousands of pages of documentsCompensation Committees throughout the world
and interview hundreds of witnesses. One corporationtoday. Directors and particularly Audit Committee and
alone has 2 million documents to review and expectsCompensation Committee members need to be
to pay $ 70 Million just to receive a Findings Report.re-educated as to governance requirements that
The purpose of the committee is to provide the Courtcomply with both the spirit and letter of the law.
with the "business judgment rule" confidence to dismissCompensation programs should not be driven by
the derivative action. However, this procedure is not ascompetitive surveys but by superior performance over
simple and straightforward as it sounds.the long-term. Full disclosure is necessary in proxy
Delaware and other states permit the board ofstatements. Independent directors are a major
directors to respond to suits by appointing an SLCnecessity. Experts have to be added to Compensation
comprised of independent directors. As long as theCommittees. If they are not there, then third parties
SLC is in process, the derivative suit is stayed.must be hired who are expert consultants. Issues of
However, in the adversarial process that is underwayIncentive Compensation, Dilution, Performance Options
continues, motions are often filed that question the trueand Structures, Repricing, and a variety of tax and
objectivity of the SLC. Delaware courts often slam thegovernance issues have to be addressed. Steps have
door to the SLC by ruling against them and letting theto be taken to ensure that Board and Committee
suit proceed. If the SLC members have significantevaluations of compensation are equitable and it would
social ties to the defendants in terms of past or futurebe advised to refrain from using company resources
relationships that is one disqualification. Another is ato satisfy legal and tax liabilities for executives who
public statement by the head of an SLC at any timeare implicated in wrongdoing. This could lead to further
prior to the issuance of the report that illustrates bias. Itderivative suits. Independent detailed investigations on a
is hard to believe this would occur but in specific casescase-by-case basis with strong Board of Director
it has and it has destroyed the company's defensesbacking need to be undertaken. The implications of
from the beginning.Sarbanes need to be fully understood and addressed.
Directors often share institutional and socialLying to auditors is now a federal offense. Insider
connections based on board service. This makes itmanipulation is now not being tolerated by the market,
particularly difficult to find objective third parties.nor by enforcement authorities who have oversight.
Warren Buffet explained it this way: "Why haveJustice officials have made it clear that executives can
intelligent and decent directors failed so miserably? Theface possible prison time for backdating stock options.
answer lies not in inadequate laws - it's always beenSerious change and corporate governance must now
clear that directors are obligated to represent thefollow.