In 2011, two federal banking agencies brought civil damage actions in the Central District of California towards government officers of failed financial institutions. In many states, including California, Delaware and New York, there was little dispute that the business judgment rule applies equally to corporate officers and administrators Law News. He currently serves as the Co-Vice Chair and Secretary of the Financial Institutions Committee of the Business Law Section of the California State Bar . He is the founder and managing companion of Joseph & Cohen, Professional Corporation () in San Francisco, CA. Mr. Joseph is a member of theCalifornia State Bar, the Washington D.C. Bar and the State Bar of New York.

• Page 27This article explores an alternate method and attainable “safe harbor” for a UCC Article 9 foreclosure sale of non-public property.
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