Risk
In judgment-driven CRA disputes, early positions and decisions drive what follows.
Ownership
Responsibility rests with leadership. Decisions, their rationale, and stakeholder communication shape both the outcome and its ability to withstand review.
Insights
In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment while information remains incomplete and positions unsettled. This does not reflect a...
In large-corporation CRA disputes, the period immediately following reassessment is defined by unresolved conditions. Information is incomplete. Interpretations remain unsettled. Exposure cannot yet...
A CRA dispute begins when CRA issues its reassessment. Management’s first test begins when it explains it to directors, shareholders, lenders, investors, or partners. The structure varies. The...
Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For...
Executive Abstract A CRA dispute unfolds across multiple institutions with different incentives and objectives. After a reassessment is issued, control over the advice and guidance shapes how the...
Peter Aprile, Senior Counsel at Counter LLP, describes three inflection points that define how CRA challenges develop and are resolved. The framework reflects insights drawn from years of...