On September 27, 2016, Principal Deputy Associate Attorney General Bill Baer delivered remarks at the annual Society of Corporate Compliance and Ethics Conference in Chicago, Illinois.  Baer began by commenting on the importance of compliance departments in “ensuring that companies develop and maintain a culture that values lawful and responsible corporate conduct . . . and identifying possible misconduct at the earliest possible stage and correcting course to minimize damage to the public, to the economy, to the federal fisc, to your shareholders and to your company’s reputation.”  Baer said that despite best efforts, compliance programs are not always successful at preventing or detecting misconduct, highlighting the “systemic abuses in the packaging and sale of residential mortgage backed securities,” which “in large part triggered” the financial crisis.  Baer said that in response to widespread RMBS abuses, the Residential Mortgage Backed Securities Working Group had “secured almost $46 billion in penalties, compensation and consumer relief relating to misconduct by ten different financial institutions.”  However, highlighting the importance of effective compliance, Baer said, “the nation would have been better served if we had not had to go down this road in the first place,”  and also said that DOJ could have resolved the RMBS cases more quickly if the financial institutions involved had agreed to cooperate earlier in the investigations.  Baer then discussed recently issued internal guidance on cooperation in civil enforcement matters.  He explained that “cooperation credit is only available where an entity has satisfied the requirements of the department’s Individual Accountability policy.”  Under the policy, Baer said, “[d]efendants that want credit for their cooperation must disclose all facts relating to the individuals involved in the wrongdoing, no matter where those individuals fall in the corporate hierarchy.”  Baer elaborated on cooperation, explaining that it should be “proactive,” and that companies will be considered for credit, “where a cooperator enables the government to pursue conduct that might not otherwise have been addressed.”  Baer also highlighted the importance of offering victim relief, stating, “a company that offers meaningful cooperation and timely victim relief should be afforded a more favorable resolution than a company that fights kicking and screaming until the end.”  In conclusion, Baer highlighted the importance of compliance officials in “establishing and maintaining a corporate culture that values business ethics and corporate responsibility,” and stated that “you will find a willing partner at the [D]epartment.”