The SEC and BAC/ML have come back to the table with a $150M settlement, plus changes in corporate governance. The $150M settlement would be put in a fund and paid out to shareholders as compensation. There is either extreme cynicism or innocence when Judge Rakoff asks, “Why should shareholders pay shareholders? There’s a circularity, at least in part, to this proposal.” Good question. Well, Judge, we all know that if they didn’t put the $150M aside, it would go to employee compensation. Even still, I’m not so sure everyone will appreciate the special $0.002 dividend (I guess it is better than being dilutive?)
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