On Thursday, June 16, the Vermont Office of the Attorney General held a conference call to discuss its 2011 Draft Consolidated Guide and the revised 2011 reporting forms. Like many of Vermont’s marketing disclosure conference calls, the call focused on the finer details of Vermont’s reporting requirements. One interesting take away, however, resulted from the enforcement discussion at the conclusion of the call. Specifically, Wendy Morgan, the Chief of the Public Protection Division of the Vermont Attorney General’s Office, mentioned that the Attorney General’s office would be paying closer attention to violations of Vermont’s gift ban, since the ban is now well established. Although Ms. Morgan’s comments suggested that company disclosures would be subject to heightened scrutiny, she also explained that the office always considers the frequency of the violation and the amount of money involved. In addition, she noted that all settlement agreements resulting from a failure to comply with Vermont’s gift ban and marketing disclosure law would be reported on the Attorney General website. In light of Ms. Morgan’s comments, one can only wonder how much enforcement there will be after the next round of reports are submitted. It also begs the question: will the Attorney General’s office focus on companies whose reports reveal potential violations or seek out companies that do not report at all?
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Is increased enforcement of Vermont’s gift ban and marketing disclosure law likely?
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Senior Patent Counsel
Royal DSM NV