On September 17, General Motors was criminally charged in the Southern District of New York with concealing a potentially deadly safety defect from its U.S. regulator, the National Highway Traffic Safety Administration (“NHTSA”), from the spring of 2012 through February 2014, and, in the process, misleading consumers concerning the safety of certain of GM’s cars.  The defect consisted of an ignition switch that had been designed and manufactured with too-low torque resistance and could therefore move easily out of the “Run” position into “Accessory” or “Off.”  When the switch moved out of Run, it could disable the affected car’s frontal airbags.  A simultaneously announced deferred prosecution agreement imposed on GM an independent monitor to review and assess policies, practices and procedures relating to GM’s safety-related public statements, sharing of engineering data and recall processes.  The DPA also required GM to transfer $900 million to the United States by September 24, 2015.  DOJ Press Release