The Department of Justice has announced a new, far-reaching policy regarding individual accountability for corporate misconduct – a change that could significantly affect the way mortgage lenders and securitization participants cooperate with the agency in criminal and civil investigations. A product of a DOJ working group, the new policy is the culmination of the DOJ’s gradual shift towards demanding greater individual accountability and addresses criticism, since the 2008 financial crisis, about the lack of individual accountability in corporate settlements with the DOJ and the Securities and Exchange Commission, particularly mortgage-related civil lawsuits. Under the new policy, corporations must provide...