This program was called the "Look-Back Program" (the Program) and afforded the firms, their partners and employees a safe harbor protection from SEC enforcement action for all but the most serious independence violations.
The conduct of the Individual Participants who are party to this agreement would have been safe harbored had such conduct been reported under the SEC Look-Back Program. Accordingly, Individual Participants argued that they should receive the same safe harbor protection afforded other members at other firms under the SEC Look-Back Program.
The general transfusion look-back program at the Alaska Native Medical Center, a midsize hospital owned by the health consortium, was successful in recruiting and screening for HCV in 54% of 1,396 persons who received blood products at the facility between 1980 and 1992 and who were targeted for contact.
The look-back program determined that 2% of 747 screened patients had chronic hepatitis C infection, Mr.
On June 7, however, the SEC announced that the Big Five had agreed to participate in a voluntary look-back program
commencing June 15.