Charting the Course for Multistate Voluntary Disclosures

Timothy P. Noonan and K. Craig Reilly are partners in the Buffalo and New York City offices of Hodgson Russ LLP, and Brandon J. Bourg is an associate in the Buffalo office. In this installment of Noonan’s Notes, the authors examine questions about eligibility, lookback periods, and other issues regarding multistate voluntary disclosure programs, and go behind the curtain to walk through how these programs generally work, as well as discuss some of the costs and benefits of taking part in them.

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