Banking Archive » September, 2023

Banking - September, 2023

342 articles

• CFTC Fines Goldman Sachs $3M Over Disruptive Trades
• CFTC Fines Goldman, JPMorgan, BofA Swap Dealers $53M
• Banks Must Continue Fighting Hedge Fund's Spoofing Claims
• Deutsche Bank ESG Fine May Be Preview Of SEC Climate Rule
• CFPB To Fight For Its Fiscal Life In High Court Grudge Match
• Upstart Holdings Can't Escape AI-Based Lending Claims Suit
• Trump To Face NY AG As 'Fraud' At Trial, His Empire At Stake
• Pro Say: A Cheat Sheet For The New Supreme Court Term
• South Korea Bank's NY Unit Fined $25M Over AML Lapses
• Up First At High Court: CFPB's Funding, ADA Tester Suits
• SEC Fines Advisers For Undisclosed Conflicts Of Interest
• How Gov't Agencies Will Fare In The Event Of A Shutdown
• Auditor's Atty Wins $2.4M Fees In Bank Whistleblowing Case
• Avoiding The Ethical Pitfalls Of Crowdfunded Legal Fees
• BofA Allegedly Failed To Pay Ex-Workers For Unused Time Off
• US Says Atty Owes $6.4M In Unpaid Employment Taxes
• Tornado Cash Saga Presents Thorny Issues For Fintechs
• SEC Sues FTX Auditor For Violating Independence Rules
• 'Administrative State' Attacks Soar To High Court Crescendo
• JPMorgan Says Couple's $20M Suit Is 'Investor's Remorse'
• Ex-Credit Union Exec's Wage Claim Barred, Mich. Panel Rules
• UK Litigation Roundup: Here's What You Missed In London
• Interactive Brokers, Others Fined $100M Total Over Texting
• DE Shaw Fined $10M For Impeding Potential Whistleblowers
• First-Time Advocates Dominate High Court's Fall Schedule
• 5 Supreme Court Cases To Watch This Fall
• Justices To Review Circuit Split Over Corp. Disclosure Duty
• Justices Will Review Timeliness Of Debit Card Rule Challenge
• Calif. Atty Avoids Malpractice Claims Over Wells Fargo Case
• USAA Gets Ex-VP's Suit Over Severance Pay Denial Tossed
• Off Lease Creditors Get Last Chance To Keep Ch. 11 Funded
• Bank Founder's Son Wants His $135M From Inheritance Fight
• CFTC Says Dealer's $21M Fraud Ripped Off Retirement Savers
• Libor-Rigging Deals Totaling $52M Get Final OK
• SEC Fines Citi Units $1.9M For Reg BI Disclosure Lapses
• OCC Has Eye On Bank Risk Management In 2024 Exam Plan
• Celsius Judge Questions Value Of Token Offer In Ch. 11 Plan
• Apple Must Face Antitrust Suit Over Mobile Wallet Market
• Deals Rumor Mill: Manchester U, Warriors, Citigroup China
• CFPB Urges 9th Circ. To Uphold $134M CashCall Restitution
• Energy Trading Cos. Must Review Electronic Comms Policies
• Judge Won't Force Utah Credit Union To Rebrand In TM Row
• US Crypto Needs Regulatory Clarity In Order To Thrive
• Appeals Court Denies Trump Bid To Stay $250M NY Fraud Trial
• Ex-Goldman Analyst Fed Stream Of Tips To Friends, Gov't Says
• NJ Broker-Dealer Accused Of Failing To Stop Impostor's Fraud
• SBF Faces 'Long Sentence,' Could Be Flight Risk, Judge Says
• Trump Cries Foul As $250M NY Fraud Trial Looms
• BofA Must Face 'Inflammatory' Suit Over Wire Transfer Fees
• SEC Doles Out $1.5M In Fines Over Insider Reporting Failures
• Full DC Circ. Won't Review Mastercard, Visa ATM Class Cert.
• Dems Urge SEC To Keep Scope 3 Disclosures In Climate Rule
• SEC Pursues Crypto Case In-House Despite High Court Battle
• Subprime Credit Card Co. Can't Boot Class Suit To Arbitration
• On Deck In JPML: Major Cyberattack, Uber Sexual Assaults
• Ex-Bear Stearns Trader-Turned-Gov't Witness Avoids Prison
• Ex-Cay Clubs CFO Tells Fla. Judge Fraud Was Only $3.4M
• 2 Cases May Expand CFPB's Reach On Deceptive Practices
• Rhode Island Bank Agrees To $9M DOJ Redlining Settlement
• Bracing For Regulatory Delays As Shutdown Looms
• Cannabis Banking Bill Advanced Out Of Senate Committee
• Gov't Shutdown Would Block New IPOs, SEC's Gensler Says
• FTC Says Celsius Founders Can't 'Jettison' Its Crypto Suit
• SG Will Argue In SC Congressional Map, Whistleblower Cases
• BlockFi's Ch. 11 Plan Confirmed With Opt-Out Releases Intact
• MV Realty Files For Chapter 11 Amid Investigations
• BofA Accused Of Hurting Credit Scores By Canceling Autopay
• Trump Found Liable For Fraud In NY Attorney General's Case
• Williams Mullen Adds Tech-Focused IP Partner In Raleigh
• 6th Circ. Urged to Toss Texas Developer's Malpractice Suit
• CFPB, FTC Actions Show Consumer Terms Need Fresh Eyes
• The 2023 Law360 Pulse Social Impact Leaders
• Why Law Firm ESG Is Likely Here To Stay
• What Large Language Models Mean For Document Review
• Jail Is No Place To Prep For Trial, Bankman-Fried Tells Judge
• Wells Fargo Settles Ex-Worker's Relocation Bonus Claims
• JPMorgan To Pay $75M To US Virgin Islands Over Epstein Ties
• Developers Guilty Of Plotting To Steal From Chicago Bank
• 'Man On The Run' Takes 1MDB Scandal To The Big Screen
• Wash. Recovers $42M In Stolen COVID Unemployment Funds
• Fresh Round Of Objections Hits Celsius Ch. 11 Plan
• KPMG Executives Want Out Of Credit Suisse Shareholder Suit
• BofA Wants 'Circular' Suit Over Card Interest Charges Tossed
• Lender Seeks Receiver For Property In $212M Loan Default
• Businessman Fights Attachment Bid In $60M Award Row
• Trusts Lose Class Cert. Bid In BNY Mellon Fund-Selection Suit
• Visa's Austin Ops Support Texas Venue For IP Suit, Co. Says
• What Could Come Of CFPB, EU Consumer Finance Collab
• Sen. Bob Menendez Blames Cuban Roots For Cash Stash
• Participating In Living History Makes Me A Better Lawyer
• Ex-Schnader Corporate Pro Joins Fox Rothschild In NY
• SEC Fines Deutsche Bank Unit $25M For ESG, AML Violations
• Gold, Cash And A Car: Gov't Has Edge In 2nd Bribery Case
• SEC Fines Broker-Dealer For Slacking On Reg BI Compliance
• SEC Suit Accuses 4 Of Taking Part In $196M Ponzi Fraud
• Investor Seeks Bank Docs Over 'Red Pants' Chair's Jet Use
• Judge Calls Some Of Trump's Args 'Crazy' In NY Fraud Case
• Goldman Sachs To Pay $12M For Trade Data Reporting Gaffes
• FDIC Names New San Francisco Regional Director
• NYC Cops' $8.7M Deal With TD Bank Gets Initial OK
• Legal Funder Says Conn. Dept. Can't Police Its 'Investments'
• NC Suit Says Underwriter Helped Insurer Cut Out Partner
• Kwok Operatives 'Materially Altering' NJ Mansion, Feds Claim
• SEC Case Receiver Sues Atty To Undo 'Fraudulent Transfers'
• Judge Delivers Clarity In Ambac RMBS Suit Against US Bank
• Chevron Doctrine Supporters Flock To High Court In Key Case
• NJ Gov. Calls For Menendez To Resign Over 'Disturbing' Charges
• Fenwick, Celebrities Seek To Toss FTX Investors' Suit
• Texas Man Pleads Guilty In Loan Scheme With Ex-Payroll CEO
• Private Equity Owners Can Remedy Law Firms' Agency Issues
• Travelers Wins Fight Over Stimulus Check Scheme Coverage
• UK Litigation Roundup: Here's What You Missed In London
• Don't Wait To Prepare For CFPB's Small Biz Lender Data Rule
• NJ Sen. Menendez Took Bribes For Egyptian Aid, Feds Charge
• Texas Judge Won't Block Biden Admin's ESG Investing Rule
• Bankman-Fried Will Stay In Jail Ahead Of Trial, 2nd Circ. Rules
• CFPB Plans Take Aim At Medical Debt Reporting, Data Brokers
• DOJ Tackling Voluntary Self-Disclosure In M&A, Official Says
• Cities Score Class Cert. In Rate-Rigging Suit Against Banks
• Cannabis-Tied Bank Fired CCO For Whistleblowing, Suit Says
• FDIC's Hill: We Can't Do Everything, Everywhere, All At Once
• 3M Will Pay $9.6M To Settle Iran Sanctions Case
• Adviser To Pay $1.5M To End Claim He Stole From MLB Client
• Celsius Reaches Ch. 11 TRO Deal With Crypto Staking Firm
• Bankman-Fried's Expert Witnesses Rejected By Judge
• Judge OKs $8M BofA Overdraft Settlement, $2.6M Atty Fee
• Judge Likely To Halt DOJ Quest For Ch. 11 BlockFi Seizure
• Ex-State Street Atty Rejoins Nixon Peabody As Legal Chief
• Democratic Bill Would 'Empower' FTC On Artificial Intelligence
• Covington Client Can Stay Anonymous During SEC Appeal
• Flagstar Bank In-House Atty Joins Comerica As CCO
• Murdaugh Admits $9M Fraud So Victims Can 'Begin To Heal'
• Ex-CFO Of Russian Gas Co. Gets 7 Years For Tax Crimes
• Deals Rumor Mill: Disney, Mallinckrodt, XFL-USFL
• Suit Alleging FDIC Overdraft Overreach May Not Make Waves
• Senate Hearing Hints At Brewing Divide Over AI Regulation
• Convicted Ex-JPMorgan Spoofer To Appeal 6-Month Sentence
• CFTC Has No Jurisdiction In Archegos Case, Judge Says
• Nationstar Says ACI On Hook For Costs After $2.3B 'Incident'
• Mastercard Gets Wawa $10.7M Data Breach Fee Suit Trimmed
• CFPB Won't Back Down From Student Loan Discharge Probe
• BlockFi Whittles FTX Ch. 11 Claim From $5B To $500M
• Edible Arrangements Can't Shake All Claims By Ex-President
• Celsius Approved To Pay Ch. 11 Fees For Employee Witnesses
• MJ Capital Board Member Gets 9 Yrs For $190M Ponzi Scheme
• Bankers Worry FCC Overreaches On Revoking Call Consent
• Sens. Pitch Revised Bipartisan Cannabis Banking Bill
• Seward & Kissel Shuffles In Enforcement, Litigation Leaders
• How To Protect Atty-Client Privilege While Using Generative AI
• Hayes Says Jurors Were Misled In Libor-Rigging Trial
• PNC Employees Ink $6.1M Deal In 401(K) Suit
• SEC Finalizes Truth-In-Advertising Rule For ESG Funds
• BofA Can't Nix Lender's Suit Over Aircraft Trust Ponzi Scheme
• Scalia's Son To Make High Court Debut In Whistleblower Case
• FDIC Hits Back At Challenge To Bank Guidance On NSF Fees
• Celsius Is In Settlement Talks On Ch. 11 TRO Changes
• SEC's 'Swing Pricing' Plan Gets Slammed At House Hearing
• Real Estate Rumors: MediaWill, Habitat For Humanity, Chirisa
• How New Lawyers Can Leverage Feedback For Growth
• Treasury Issues Recommended Net-Zero Emissions Principles
• Murdaugh Strikes Plea Deal For Charges Of Defrauding Clients
• Key Elements Of The Proposed Credit Card Competition Act
• 2nd Circ. Unlikely To Free Bankman-Fried After Diary Leak
• Takeaways From Recent Developments In Bank-Fintech Space
• Morgan Stanley Hit With $750M Suit Over Loan Restructuring
• Big Banks Financed Vale's Pollution Of Brazil, Suits Say
• Energy Co. Shareholder Gets OK For $151M Freezing Order
• NY Regulator Looks To Beef Up Crypto Listing Standards
• Wells Fargo Beats $800M Investor Suit Over 2018 Fund Purge
• US Wants $15M Suit Against IRS Agent Tossed
• Judge Grants NY AG Win In Small Biz Predatory Lending Case
• FTC Warns 5 Tax Prep Firms Against Improper Data Sharing
• Cooley, Latham Steer Delivery App Instacart's $660M IPO
• JPMorgan Can't Ax Ex-Worker's $1.4M Arbitration Award
• Catching Up With Delaware's Chancery Court
• NFL QB And Influencers To Settle In FTX Collapse Suit
• Some Foreign Cos. To Report Beneficial Owners, FinCEN Says
• A Cautionary Tale Of Flawed Debt Accounting And SEC Fines
• ESG Around The World: Australia
• Epstein Victim Attys Want $22.5M Fee In Deutsche Bank Deal
• USPS Worker, Spouse Cop To Stealing $8.8M In Mailed Checks
• Home Point Cuts $5M Deal With Investors Jilted After IPO
• Covington Won't Appeal Order In SEC Suit, But Its Client Might
• High Court's New FCA Ruling Is Quickly Making Trials Likelier
• Calif. 'Delete Act' Targeting Data Brokers Heads To Governor
• Puerto Rico Bank In Bribery Scandal Fined $15M By FinCEN
• Ex-Wells Fargo Exec Avoids Jail For Role In Fake Accounts
• Tesla, Musk Tell 9th Circ. To Snuff Ex-Worker's Retaliation Suit
• TelexFree Victims Gave 'Incomplete' Docs, Wells Fargo Says
• Ex-Exec Must Repay Tool Co. For Home Loan, NC Suit Says
• Firm's Debt Collection Did Cause 'Slight' Harm, Judge Says
• Del. Corporate Law Overhaul Delivers On Flexibility For Cos.
• Ex-Deutsche Banker To Change Plea In Crypto Fraud Case
• Connecticut Firm Must Face Trial In Suit Over Email Hack
• Chancery Denies Bid To Fast-Track Marqeta Buyback Suit
• Trump Seeks Delay Of NY Fraud Trial, Aims To Nix Claims
• UK Litigation Roundup: Here's What You Missed In London
• 9 Consumer Finance Issues To Note From CFPB Report
• SEC Looks Ready To Greenlight 'Greenwashing' Rule
• FTX Says BlockFi Trying To Dodge Claims In Ch. 11 Plan
• Republicans Rip 'Extreme' Bank Capital Plan As Dems Waver
• First Post-Cochran Suit Against SEC In-House Courts Dropped
• Debt Collector Violated Collection Rules, Fla. Consumer Says
• Ex-Morgan Stanley Broker's $8.8M Recruiting Loan Case Axed
• New US Sanctions Target Russian Equipment, Service Cos.
• Archegos Duo Can't Subpoena Fraud Victims, Feds Say
• 'As Bad As It Gets': Thieving Murdaugh Pal Hit With 20 Years
• CFPB's Small-Biz Loan Rule Paused Until High Court Ruling
• Wash. Justices Say CEO Can't Skip Deposition In Bank Case
• Compliance Hires Roundup: Regions Bank, Enbridge & More
• Sbaiti To Lead Barclays Unregistered Securities Investor Suit
• ArentFox Schiff Adds Ex-Fannie Mae Finance Atty In SF
• Payment Tech Co. Plastiq Gets OK On Ch. 11 Plan
• Twitter Legal Fees Suit Offers Crash Course In Billing Ethics
• Blockchain Tech's Role As A Driver Of M&A Action Evolves
• New York Trial Atty Leaves Stroock For Crowell & Moring In NY
• Biz Groups Urge CFPB To Not Go After Medical Credit Cards
• SEC's Gensler Warns Of Potential AI-Driven Financial Crisis
• Chopra Says CFPB High Court Loss May Risk Housing Havoc
• Hilton, Fallon, Bieber Want Out Of Bored Ape NFT Suit
• Empower Finance App Can Keep Its Name, For Now
• Kirkland Lands $28M In Fees In Crypto Broker Voyager Ch. 11
• FTX Gets Go-Ahead To Sell $100M In Crypto A Week
• The Long Reach Of Proposed Security-Based Swaps Rule
• How 2nd Circ. Ruling Fortifies Plaintiff Standing Arguments
• BofA Inks $8M Settlement With Customers In ACH Fee Suit
• Regulators Must Avert Overreach When Targeting AI
• Calif. Lawmakers Pass Pioneering Carbon Disclosure Bill
• 4 Questions About CFPB's Defeat On Anti-Bias Exam Policy
• HNA Seeks 2nd Circ. Reversal Of $185M Award
• Judge Lets Treasury Withhold Sanctions Info From Law Firm
• Adviser To Sport Stars Settles SEC's Registration Claim
• Influencer To Pay Up To End Pa. AG's Suit Over Ad Scam
• Bankman-Fried Can't Get Out Of Jail To Prep For Trial
• Organizations Urge Texas Courts To Curb 'Judge Shopping'
• PacWest Investor Says Bank Understated Rate Hike Exposure
• SEC's Gensler Calls On Congress To Fund AI, Crypto Efforts
• Deutsche Bank Can't Undo $95M Verdict Over Ponzi Scheme
• SEC Sues Virtu Over Information Security Safeguards
• The Benefits Of Preparing OFAC's Blocked Property Report
• Transaction Risks In Residential Mortgage M&A Due Diligence
• Former FTX GC Taps Crisis Experience To Build New Boutique
• Former Acting OCC Head Rejoins O'Melveny As Fintech Pro
• SBF Cites 5th Amendment In Bid To Stall FTX Customers' Suit
• Retail Lessor Banned In $36M Deals With CFPB And States
• Fulton Bank To Settle Third-Party Breach Suit With Borrowers
• Former Exec Escapes Investor Challenge To $1.1B 'Sham' Deal
• Off Lease, Ally Bank Work On Deal For Cash Use In Ch. 11
• Voyager Reaches Post-Confirmation Intercompany Claim Deal
• Catching Up With Delaware's Chancery Court
• Mark-To-Market Appropriate For Crypto Traders, Tax Attys Say
• FTX Sues To Claw Back $100M From Virgin Islands Firm
• Developers Embezzled Millions From Chicago Bank, Jury Told
• ABA's Money-Laundering Resolution Is A Balancing Act
• FCRA Legislation To Watch For The Remainder Of 2023
• CFPB Loses Texas Court Battle Over Anti-Bias Exam Policy
• FDIC Admits It Flubbed Some Of Its First Republic Oversight
• Fed Official Says Stablecoin Policy Isn't 'Hurdle' To Banks
• FDIC Asks Judge To Nix Venture Capitalist's Suit Against SVB
• Wells Fargo Investors Land Final Approval Of $1B Deal
• FinCEN Calls On Banks To Spot 'Pig Butchering' Red Flags
• 2 High Court Cases Could Upend Administrative Law Bedrock
• 5 Charged Over $600M Diamond District Transactions
• Trump Overstated Net Worth By Up To $3.6B, NY AG Alleges
• $1.5M Deal In Bank Of America Break Suit Gets Initial OK
• With Equity Markets Down, Venture Lending Provides Solution
• UK Litigation Roundup: Here's What You Missed In London
• 2nd Circ. Says REIT Can't Open 'Backdoor' To Suing Advisers
• NY Credit Union Gets Final OK On $2.2M Overdraft Fee Deal
• Fla. Judge Says State Owes No Interest On Unclaimed $26.24
• Quantum Computing Poses Cyber Risk, Fed Official Warns
• Failed Bank's Ex-CEO Gets 14 Years, Owes $215M For Fraud
• CFPB's Chopra Warns Of Big Tech's Grip On Mobile Payments
• CFTC Lands $1.7B Settlement For Mirror Trading Bitcoin Case
• Ex-Traders At 7th Circ. Deny Knowing Spoofing Was Criminal
• Real Estate Rumors: Bennett, Kushner, Mesa West
• Del. Justices Mostly Back Chancery On 'Incurable Voidness'
• Regulators Should Unmask DeFi Operators, Global Body Says
• BofA Reaches Deal In ADA Suit Over Remote Work
• Law Firm Professional Development Steps To Thrive In AI Era
• Fla. Court Says Attys Don't Have To Pay Fired Counsel's Fees
• Securities Firms Sichenzia Ross, Carmel Milazzo To Merge
• Fox Rothschild Adds Trust And Estates Partner In Del.
• Ex-3rd Circ. Judge Joins Blank Rome From Schnader Harrison
• Deals Rumor Mill: Great Wall Motor, Carlyle, Amer Sports
• Previewing Big Changes To NY's Finance Cybersecurity Rules
• Ex-FTX Exec Cops Plea, But Not Cooperating Against SBF
• SBF Can't Go Free While Appealing Detention, 2nd Circ. Says
• CFPB Rips Kentucky Banks' Bid To Halt Small-Biz Loan Rule
• Fired Wells Fargo Exec Fights To Keep Retaliation Suit Alive
• Accounting Board Updates Standards For Crypto Holdings
• FTX Examiner Report OKs $111M In Professional Fees
• $20.9M FBAR Penalties Don't End With Texaco Heiress' Death
• Colo. Gov. Urges Biden To Adopt Cannabis Reform
• NJ Gov. Nominates New Banking And Insurance Regulator
• Lessons From High-Profile Witness Tampering Allegations
• Trump Can't Delay Oct. Trial In NY AG's $250M Tax Fraud Case
• Payroll Tax Evasion Notice Suggests FinCEN's New Focus
• Conn. Banking Dept. Wants Panel To Hear Debt Law Firm Case
• Real Estate Rumors: Keystone Financial, Ram Realty, Ryan
• Understanding China's Crypto-Blockchain Dichotomy
• Citi GC Rejoins Shearman & Sterling As Of Counsel
• Okla. Bank Customers Get Initial OK For $1.5M Overdraft Deal
• Biden's 3 Fed Picks Clear Final Hurdles As Senate Confirms
• Ruling Clarifies Bankruptcy Courts' Class Action Jurisdiction
• SEC's New Rules Likely Will Affect Cyber, D&O Insurance
• If Binance Criminally Charged, Crypto Exchanges May Exit US
• Chase Bank Must Face Calif. Law Firm's Probate Funds Suit
• Malaysia Says Feds Flouting Deal To Return Ex-Goldman Exec
• Judge Questions Gordon Rees Moves In Crypto Client Dispute
• Wells Fargo Must Produce Docs in TelexFree Suit, Judge Says
• FDIC Dings Fintech Bank Over 'Illegal' Credit Practices
• EU Competition Commissioner Vestager To Step Aside
• 1 Year Sought For Ex-Wells Fargo Exec In Fake Account Case
• Umpqua Bank Hit With Class Action Over MOVEit Breach
• Bankman-Fried Jail Appeal 'Trivializes' Diary Leak, Feds Say
• How Regulation E Could Complicate Crypto Compliance
• Murdaugh Accuses Clerk Of Jury Tampering, Seeks New Trial
• Ex-CFTC Whistleblower Chief Joins Phillips & Cohen
• Potential Marijuana Status Change Would Shift Industry Risks
• Trump, Attys Need Sanctions For Rehashed Args, NY AG Says
• Ex-SEC Enforcement Atty, SVB Counsel Joins Venable In LA
• Schumer Framework May Forge US Model On AI Governance
• CFPB Will Settle Employees' Race Discrimination Suit For $6M
• Covington Ruling Strengthens SEC's Enforcement Powers
• SEC Says Man Used Trickery To Pump JC Penney Debt Shares
• Discover Hit With Investor Suit Over Compliance Woes
• Banks' $500M Stock Loan Antitrust Deal Gets Initial OK
• Ponzi Schemer Stanford's Early Release Bid Denied Again
• Feds Eye 5 Years For Instagram Influencer's $1M COVID Scam
• Judge Blocks Treasury Dept.'s Lender Decertification For Now
• Best Practices For Lenders To Limit Recourse Liability
• Senior Home Operator To Pay $4.25M In FCA Kickback Case
• Credit Suisse Whistleblower Asks 4th Circ. To Revive Tax Suit
• Schumer Lays Out Senate's Post-Recess Priorities
• Conn. Lawyer Says Colo. Companies Stiffed $107K Legal Bills
• NJ Must Pay $1.3M Counsel Fee In Election Law Fight
• Occidental Scores $1.5M Atty Fees In Wells Fargo Dispute
• 2nd Circ. Ruling Is Good For Syndicated Lending Stability
• Fair Lending Activity: Calm On The Surface, Churning Below
• Attys Prepare For IPO Pickup As Market Shows Signs Of Life
• Nonbank Payment Apps Face More Regulatory Scrutiny