New York counsel John Nathanson and New York associate Colin Cassedy published an article in the New York Law Journal titled "SEC Cooperation Initiative: Game Changer or Preserving Status Quo?" The article looks at the impact of the SEC's Cooperation Initiative, announced 22 months ago, which was designed to encourage individuals and companies to assist with investigations by rewarding cooperation. In the authors' view, "Nearly two years after its enactment, the Cooperation Initiative does not yet appear to be the 'game-changer' that Mr. [Robert] Khuzami [Director of the SEC's Division of Enforcement] envisioned, in part due to a lack of transparency into the SEC’s decision-making process. With little precedent available to shed light on how much and what type of cooperation is required to obtain cooperation credit, the precise nature of the benefits a cooperating witness may receive remains unclear." In the end, they say, "For the Cooperation Initiative to be a success, the SEC must disclose the precise nature of the cooperation provided by subjects and the benefits received (including any assurances from the Justice Department)."