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Today, at a Board meeting that was again closed to the public over my objections, the Board finally reached consensus on how to investigate allegations of misconduct by �౦��Ϸ���� executives.¹ This belated consensus follows five months of debate, delays, and false starts.

Under the approach adopted today, the newly established Office of Professional Conduct (OPC) will retain and oversee law firms that will investigate allegations of executive misconduct.² Hopefully, we can expect completed investigations in the spring, with disciplinary decisions not long after that.

The problem of course is that will be too little too late. Thanks to months of debate, delays, and false starts at the Board level, accountability for wrongdoing will be delayed until a year after the Cleary report and likely after some of these executives have left the �౦��Ϸ����. There can be no doubt that, despite my and Vice Chairman Hill’s persistent efforts, �౦��Ϸ���� leadership has failed to deliver prompt accountability.

Some might ask what happened to the Board majority’s 3-2 decision in August to outsource these investigations to a to-be-determined government agency. That approach proved unworkable. Even at the time of its adoption, the Board majority knew there were very significant obstacles to its success.³ The decision to pursue this half-baked approach was, at a minimum, a serious error of judgment.

On a more positive note, we have hopefully put an end to months of dithering and dilly-dallying on accountability.⁴ All that was totally unnecessary. But all that was also totally inevitable. 

This has been a Board haunted by the legacies of the past and the associated conflicts of interest. 

With the establishment of the OPC, and also with the potential for an imminent fresh start at the �౦��Ϸ����, I am optimistic that the �౦��Ϸ���� will eventually put itself on a path to true change and actual accountability. The �౦��Ϸ���� employees and the American public deserve no less.