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Doing the Right Thing: Bank Ones Response to the Mutual Fund Scandal
Introduction
Jamie Dimon, CEO of Bank One Corporation, sipped his coffee in the boardroom of J.P. Morgan Chase & Co. while he waited for William B. Harrison, Jr. to arrive. Although the merger between their two banks wouldnt be finalized for a few more days, he felt at home in the World Headquarters building at 270 Park Avenue in midtown Manhattan. It was good to be back in New York. Hed left the city and number two position at Citibank after a falling out with its CEO, Sandy Weil, in 1999. A year later, Dimon became CEO of Bank One and moved to Chicago. The merger of Bank One and J.P. Morgan Chase would be finalized on July 1, 2004, creating the second largest financial institution in the world. Mr. Harrison, CEO of J.P. Morgan Chase, had called the meeting today with Mr. Dimon to discuss the final settlement of the charges brought by the Securities and Exchange Commission (SEC) and New York State Attorney General Eliot Spitzer against Banc One Investment Advisors Corporation. As he waited for Harrison, Dimon went over the events of the last ten months that had rocked the pristine mutual fund industry. The widespread probe into trading practices could have tarnished Bank Ones reputation in the financial community. Dimon was relieved that the situation would be resolved shortly. He was ready to brief Harrison on the final details of the settlement before it became public.

Background of the Investigation

In September 2003, the mutual fund scandal started when Bank One, Bank of America, Janus, and Strong Capital came under investigation for improper and/or illegal trading practices. They were named in a complaint brought by the SEC and Eliot Spitzers office against Canary Capital Partners. Bank One was the last of the four companies to reach a settlement with the SEC. Under pressure to reach an agreement before the merger with J.P. Morgan Chase took place, Bank One agreed to a $90 million settlement. Although the company neither admitted nor denied wrongdoing, it agreed to pay $50 million in fines and restitution, and reduce fees charged to investors in its mutual funds by $40 million over the next five years. In addition, Mark Beeson, former head of Bank Ones mutual fund division, agreed to pay a $100,000 fine. He was also banned from the industry for two years. Bank Ones $90 million settlement was considerably less than the $675 million in fines and restitution that Bank of America/Fleet Boston paid for its role in the scandal. Like Bank One, Bank of America reached an agreement with the SEC just before its merger with Fleet Boston took place. Bank of America paid a higher price because of a broader case in which one of its brokers faced criminal charges. The scandal spread far beyond the four companies named in the complaint against Canary Capital. Less than a year after the original charges were brought, dozens of mutual fund companies had paid over $2.5 billion in fines, restitution, and fee cuts (Brewster, 2004).
Copyright 2004 Thunderbird, The Garvin School of International Management. All rights reserved. This case was prepared by Professor Christine Uber Grosse for the purpose of classroom discussion only, and not to indicate either effective or ineffective management.

Nothing is more important to us than maintaining the highest ethical standards. (Jamie Dimon, September 9, 2003)

Long known in the financial community for his integrity, Dimon addressed the allegations of improper trading as soon as they became public in September 2003. Quickly, he developed a strategy that involved cooperation, transparency, and communication to lead the bank out of the crisis. He focused on doing the right thing, a value he consistently emphasized at the bank. In a message to employees, Dimon (September 9, 2003) wrote, At Bank One we talk a lot about doing the right thing, and I promise we will do the right thing in this situation. In the same message, Dimon outlined the steps that Bank One would take to respond to the mutual fund scandal. Echoing the theme of doing the right thing, Dimon wrote, Nothing is more important to us than maintaining the highest ethical standards. He also emphasized that the bank took its responsibility to shareholders very seriously. He mentioned that the bank shared the interest of the New York Attorney General and regulators to safeguard the integrity of the mutual fund industry. Dimons message to employees established the major components of his strategy that were followed throughout the crisis: Do the right thing Maintain the highest ethical standards Take the banks responsibility to mutual fund shareholders seriously Cooperate fully with the New York Attorney General and regulators Review and evaluate policies and procedures quickly and thoroughly Take disciplinary action as needed against employees Make restitution to shareholders Communicate and promote transparency

Dimon promised a swift and thorough gathering of the facts. In the interest of transparency and communication, Dimon pledged to communicate with bank employees and mutual fund shareholders as appropriate, and encouraged bank employees to share his letter with any Bank One customers who were interested. However, Dimon requested employees to withhold comment or speculation until the investigation uncovered the facts. He also asked for their patience, since it would clearly take some time before the investigation was completed. Throughout the crisis, the bank adhered to the basic strategy outlined in that letter to employees. How well did his strategy pay off? Did his leadership, commitment to doing the right thing, transparent action, and communication help Bank One to regain customer trust and move beyond the mutual fund scandal?

About Bank One and J.P. Morgan Chase & Co.

Bank One Corporations wholly owned indirect subsidiary, Banc One Investment Advisors (BOIA), came under investigation in the mutual fund probe. BOIA offered investment management services, including One Group Mutual Funds, to individuals and companies. One Group Mutual Funds managed over $100 billion in assets. BOIA, whose headquarters were in Columbus, OH, registered with the SEC as an investment adviser on November 22, 1991. BOIA was a wholly owned subsidiary of Bank One, National Association (Ohio), which in turn was a wholly owned subsidiary of Bank One Corporation. Before its merger with J.P. Morgan Chase & Co. on July 1, 2004, Bank One was the sixth largest bank in the United States, with assets of around $320 billion. Bank One served about 20,000 middle market clients and approximately seven million retail households. The bank issued over 51 million credit cards and managed investment assets of about $188 billion.
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On July 1, 2004, Bank One merged with J.P. Morgan Chase & Co. The combined financial services firm had assets of about $1.12 trillion. Operating in over 50 countries, the company provided financial services for consumers and businesses, investment banking, asset and wealth management, financial transaction processing, and private equity. With corporate headquarters in New York, J.P. Morgan Chase would maintain headquarters for U.S. retail financial services and commercial banking in Chicago (Wall Street Journal Online, 2004).

Situation Leading Up to the Scandal

On September 3, 2003, New York State Attorney General Eliot L. Spitzer and the SEC brought charges against Canary Capital Partners, a hedge fund, for illegal after-hours trading and improper market timing. In this complaint, Bank One and three other mutual fund firms were named for making special deals with Canary to conduct the improper mutual fund trades. Probes into mutual fund trading focused on late trading and market timing. Late trading, an illegal practice, occurs when mutual fund orders that are placed after 4 p.m. are processed at the sameday price rather than the price set on the following day. Law requires that late trades be placed at the following days price. Although market timing, also known as timing, is not illegal, many mutual fund prospectuses discourage investors from doing it. Timing involves the rapid buying and selling of mutual fund shares by short-term investors who try to take advantage of inefficiencies in the pricing of mutual funds. Timers hope to profit from fund share prices that lag behind the value of the underlying securities. Share prices of mutual funds are set at 4 p.m. Eastern Standard Time (EST) based on the values of their portfolio holdings. Any trades placed after 4 p.m. EST are supposed to be charged at the next days prices to keep investors from taking advantage of news that happens after the close of trading (Carey, 2003). Like many other funds, One Group Mutual Funds had policies that discouraged market timing, because it skimmed profits from the accounts of other shareholders. By giving special permission to certain large investors to market time, BOIA earned higher management fees from those investors accounts (Lauricella, 2004). Market timing could hurt long-term investors by driving up costs and reducing their profits (Johnson, 2003). The rapid in-and-out trading can cause an increase in transaction costs since the portfolio manager may have to buy and sell securities in response to the hedge funds trades. These costs are normally borne by the mutual fund. In addition, the dilution effect occurs when the fund has to pay for the timers profits out of its own finite pool of assets (Carey, 2003). The profits usually are paid from the funds cash holdings or a sale of securities to cover the payment. In either case, shareholders are hurt because the total amount of assets available in the mutual fund is diminished. Some blame the practice of market timing on stale pricing. Since mutual fund prices are only adjusted once a day, they frequently go out of date, hence stale. The funds underlying securities change value throughout the day, and may be spread across different time zones. Large investors can use sophisticated technology to take advantage of the differences between the prices of the funds shares and the funds assets (Arizona Republic, 2003). The effects of Canarys market timing apparently took a toll on Bank One mutual fund managers. According to the Canary settlement document, the managers complained to One Group President Mark Beeson about the impact of Canarys timing activity on their funds (Atlas, 2003). In April 2003, Canary stopped trading in Bank Ones mutual funds when Beeson no longer felt comfortable waiving penalties for their frequent trading.
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One Group Restrictions against Timing

Mark A. Beeson held the positions of President and CEO of One Group from January 2000 until his resignation in October 2003. In 1994 Beeson began working at BOIA as the chief financial officer. After two years he was promoted to chief administrative officer. From June 2002 until May 2003, Mark A. Beeson and One Group allowed Canary Capital to make 300 buy-and-sell transactions in several domestic and international stock funds. Canary earned a profit of around $5.2 million from this market timing. In addition, Canary was not charged around $4 million in penalties that it should have paid for market timing (SEC Order, 2004). Prospectuses in the One Group put restrictions on excessive exchange activity in all the One Group mutual funds. Exchange of any investment in the funds was limited to two substantive exchange redemptions within 30 days of each other. In November 2001, One Group set a 2% early redemption fee for any international fund redemption made within 90 days of purchase. It also reserved the right to refuse any exchange request that would negatively affect shareholders. In fact, over 300 exchange privilege violations were identified by Beeson and BOIA between January 2002 and September 2003 (SEC Order, 2004). Late in 2001, Edward Stern, head of Canary Capital, made a proposal through Security Trust Corporation to BOIA. He offered to borrow $25 million from Bank One and match it with $25 million of his own funds if he were allowed to trade in certain mutual funds. Beeson refused the proposal several times. But after talking it over with Security Trust Corporation and Bank One employees, Beeson decided to consider letting Stern trade in certain Bank One funds in March 2002. Although Bank Ones chief operating officer advised against it, Beeson allowed Edward Stern to trade in several domestic and two international funds for up to half of one percent of the funds value. For trading purposes, Bank One loaned $15 million to Stern, who matched it with his own $15 million. Stern agreed that the entire amount would stay within Bank One as security for the loan. BOIA did not charge Stern the 2% redemption fee normally required for any trade made less than 90 days after an initial purchase. This would have amounted to around $4.2 million in redemption fees. In January 2003, Stern received a second Bank One loan of $15 million, which he again matched with $15 million of his own funds. He also used this money to trade in One Group funds. Between June 2002 and April 2003, Stern earned a net profit of about $5.2 million from approximately 300 in-andout trades. From this arrangement, Bank One gained the interest on the loans and BOIA increased mutual fund sales and associated fees. According to the SEC settlement document (2004), the agreements with Canary Capital were never discussed with the One Group Board of Trustees. Another possible reason why Beeson agreed to the arrangement was the hope of doing future business with Stern. On several occasions, he discussed Sterns possible investment in a Bank One hedge fund, but that investment never took place (SEC Order, 2004). Other customers besides Canary Capital received special treatment from BOIA. Apparently without Beesons knowledge, a Texas hedge fund was excused from paying the 2% redemption fee in March 2003. Although the Texas company invested $43 million in two international funds and redeemed the investment three days later, it did not have to pay about $840,000 in redemption fees. BOIA did not reimburse the two international funds for the fees that it didnt collect. As standard procedure, the portfolio holdings of One Group mutual funds were considered confidential information that was published only as required by law. Nonetheless, Stern asked for and received monthly updates on the eight funds in which he had investments from July 2002 until April 2003 when the relationship ended. Beeson provided him with this information without any confidentiality agreement. The investigation also found that BOIA provided One Groups portfolio holdings to
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other special clients over a period of ten years. This information was given out as often as once a week to seven clients, eight prospective clients, and several dozen consultants from pension funds or fund advisers. The special trading arrangements for Stern and others began to unravel in July 2003. Noreen Harrington, a former Hartz investments officer, blew the whistle on improper trading practices at Canary Capital. She quoted Eddie Stern as saying, If I ever get in trouble, theyre not going to want me, theyre going to want the mutual funds (Vickers, 2004). New York Attorney General Eliot Spitzer subpoenaed Stern and named him in a complaint for having engaged in fraudulent schemes of late trading and market timing of mutual funds. Two months later, Canary Capital settled with the SEC and Attorney Generals office for $40 million. Canary agreed to pay $30 million in restitution for profits gained by improper trading, as well as a $10 million penalty. Canary neither admitted nor denied wrongdoing.

The Mutual Fund Industry

Shock waves hit Wall Street when Spitzers investigations began into trading abuses in the mutual fund industry. Few outside the financial community expected to see a scandal occur there. As the probe continued, it uncovered improper trading practices at dozens of mutual fund companies. New York Attorney General Eliot Spitzer called the industry a cesspool (Waggoner, Dugas & Fogarty, 2003). Half of the 88 largest mutual fund groups had permitted favored investors to buy mutual fund shares at stale prices, skimming profits from long-term shareholders (Quinn, 2003). Pricing had been an issue in the mutual fund industry for a long time. In the 1930s, mutual funds often had two prices: a public price, as well as a more up-to-date price that a few big investors could access just before the price became public. The privileged investors who knew where mutual fund prices were going could make fast profits. In response, Congress passed the Investment Company Act of 1940 in an attempt to make mutual fund pricing policies fairer. Among other rules, it required funds to have just one public price. According to Mr. Spitzer, mutual fund companies made over $50 billion in management fees in 2002. He was the first to suggest that the widespread practice of preferential trading for big investors could be channeling billions of dollars away from everyday long-term investors in mutual funds. Mr. Spitzer commented on ways that companies could make amends. If theyre expecting to get settlements (with regulators), theyre going to have to give much more back than just (investors) losses. Theyre going to be paying stiff fines and giving back their management fees. They violated their trust with the American investor (Gordon, 2003). Spitzer also expressed dissatisfaction with the SECs oversight of the industry. Paul Roye headed the mutual fund division of the SEC. Heads should roll at the SEC. There is a whole division at the SEC that is supposed to be looking at mutual funds. Where have they been? According to SEC Chairman William Donaldson, the SEC was considering new curbs on fund trading (Gordon, 2003). The question remained how the scandal would affect the mutual fund industry. Arthur Levitt, former SEC chair, said, This seems to be the most egregious violation of the public trust of any of the events of recent years. Investors may realize they cant trust the bond market or they cant trust a stock broker or analysts, but mutual funds have been havens of security and integrity (Lauricella, 10/20/03). How many of the 95 million customers would cash in their shares? Investors apparently didnt lose faith in all mutual funds. John C. Bogle, founder of the Vanguard Group, believed that money was flowing out of companies that had lost investor confidence and into companies that had kept their good reputations for being well managed or holding down costs and fees (Lauricella, 10/20/03).

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Indeed, stock funds gained $23.2 billion in December 2003, up from $14 billion in November 2003, according to AMG Data Services in Arcata, California. More than half of the new money went into three funds which were not implicated in the investigations: Fidelity, Vanguard, and American Funds (McGeehan, 2004). As of November 2003, Putnam lost a net $11.1 billion from its stock funds, while investors withdrew about $2.2 billion from Janus Capitals stock funds. Much of that may have been reinvested in other mutual funds.

Developments at Bank One

Bank One took a number of actions as the investigation progressed. Several weeks after the probe began, Mark Beeson, the head of One Group, resigned. To replace him, Dimon appointed Dave Kundert, head of the banks investment management group. Peter C. Marshall, Chairman of the Board of Trustees of One Group Mutual Funds, sent a letter and prospectus supplement on October 10, 2003, to all mutual fund customers informing them of the complaint filed by the New York State Attorney General against Canary Capital Partners, LLC. The prospectus supplement included detailed information about legal proceedings related to the complaint which found that Canary engaged in improper trading practices with certain Bank One mutual funds. In the letter Marshall wrote, Nothing is more important to your Board than to get all the facts and to resolve this matter as soon as possible (Marshall, 2003). He echoed Jamie Dimons commitment to find out the facts quickly and do the right thing. He informed shareholders that a special review committee had been created to help gather and review information concerning the alleged trading activities. He assured the shareholders that they would receive restitution if they had been harmed by the wrongful conduct of any Bank One employee. Furthermore, he made it clear that every member of the One Group Board of Trustees was independent. As Jamie Dimon had done in September, Marshall affirmed that the Board was committed to meeting the highest standards in the industry and putting shareholders interests first. Shortly after Marshalls letter came out, Jamie Dimon sent an e-mail update to employees concerning the mutual fund investigation (October 15, 2003). He summarized the key findings. Canary Capital Partners hedge fund was allowed to trade eleven One Group funds more often than other customers over an 11-month period ending in May, 2003. The investment by Canary averaged 0.5% of the funds assets and never went over 1%. Dimon regretted the special arrangement with Canary and stated that it never should have happened. The investigation into whether shareholders were financially harmed was continuing. The bank would make full restitution if it found this to be true. They would continue to see if other clients had similar arrangements, but so far they had not found the problem to be widespread or systemic. Bank One terminated its contract with Security Trust Company, a back-office firm that processed Canarys transactions in One Group mutual funds. Although it was not accused of any wrongdoing in Spitzers suit, the firm could not assure Bank One that they had abided by their contract, which stated that the only trades that could be sent to One Group for same-day pricing were those received prior to market close. No evidence was found that Bank One or Bank One employees made after-market trading arrangements. Next, Dimon announced five changes that would strengthen oversight and transparency of mutual fund policies and procedures at Bank One. First, Dave Kundert took over as President of One Group. Second, the bank implemented improved computer monitoring and compliance measures. Third, employees would receive internal training on how to identify inappropriate timing practices. Fourth, the bank enhanced agreements with service providers to receive assurance that they had internal policies and controls to prevent going around One Groups policies concerning market timing and

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excessive trading. Fifth, the bank continued to review mutual fund policies in order to meet the highest standards. As he had done in a previous message, Dimon promoted transparency and communication by encouraging employees to share his letter with any Bank One customers who had questions. He also promised to give additional updates as appropriate.

Taking the Matter Seriously

It was important for Bank One to convince the SEC, shareholders, and customers that it was taking the charges seriously. As a result, this theme appears in each public communication from the Bank. In Marshalls letter to One Group Shareholders( 2003), he emphasizes how seriously the Board of Trustees is taking the matter. On behalf of the One Group Board of Trustees, I want to convey to you the seriousness with which your board takes its responsibility to One Group mutual fund shareholders. Dan McNeela, an analyst for Morningstar, Inc., responded to Dimons personnel changes and plans for change. This confirms our opinion that Jamie Dimon is taking the matter seriously, but it may not be enough simply to ask a couple of executives to leave and say everything is okay (Manor, 2003). Dave Kundert, President of One Group Funds, addressed the mutual fund scandal at Bank One in a message sent to employees on November 26, 2004. He explained that it was likely that the bank would face enforcement action against Banc One Investment Advisors. However, he expressed optimism that we can avoid regulatory litigation and reach an amicable resolution with the regulators over the next several months. Kundert outlined to employees the broad changes in policies and procedures that Bank One had recently implemented in the One Group mutual funds. They had established a 100% independent Board of Trustees. They would continue to cooperate with the Attorney Generals and SECs investigations. After holding a public dialog on best practices in the industry, they selected and implemented a number of best practices which included the following: Hiring a new compliance officer Increase training for employees Disclosure of more information about fund managers salaries Change how research fees are negotiated, paid, and disclosed to investors (Johnson, 2003) Addition of redemption fees to certain funds Allow employees of the fund company to only buy One Group fund shares through Banc One Securities Corp. accounts or One Group, and require holding the One Group funds for at least 90 days (Shipman, 2003) Disclosure of portfolio holdings quarterly on the fund companys Web site Cap individual purchases of Class B shares. These shares had a back-end sales charge and higher expenses than Class A shares, which had a front-end charge that declined as people invested more (Stempel, 2003) Richard Bove, analyst at Hoefer and Arnett, confirmed that Jamie Dimon has indicated that if Bank One had done anything inappropriate, he would take any action necessary to correct what was wrong. He commented that its pretty clear that Bank One will pay sizable fines, not because it did anything malicious but because of a lack of control (Stempel, 2003). On a conference call discussing third quarter earnings with executives at Bank One Corporation, Jamie Dimon reaffirmed his commitment to doing the right thing. I look at this as a chance for Bank
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One, even though we made some errors here, to earn your and our customers respect by standing tall and doing the right thing, and not only look at these problems, (but try) to improve other things that should be fixed in the mutual fund business (Siegel, 2003).

Settlement Agreements
On June 29, 2004, Banc One Investment Advisors agreed on a settlement with the Securities and Exchange Commission and the New York Attorney Generals office concerning issues related to One Group mutual fund trading. The mutual fund unit of Bank One had allowed improper short-term trading of its fund shares at the expense of other shareholders. According to Stephen Cutler, director of the SECs division of enforcement, Bank One and Mark Beeson blatantly disregarded the well-being of One Group funds long-term shareholders (Lauricella, 2004). Bank One agreed to the settlement without admitting or denying any wrongdoing. Philip Khinda, counsel to the One Group of funds and their board of trustees, commented on the settlement agreement. Its a very fair result and a product of the commitment of everyone involved to doing right by the shareholders of the funds (Lauricella, 2004). The Securities and Exchange Commission found that Banc One Investment Advisors (BOIA) and Mark Beeson, President and Chief Executive Officer of One Group Mutual Funds and a senior managing director of BOIA, violated and/or aided and abetted or caused violations of the antifraud provisions of the Advisers Act and the Investment Company Act by the following: 1. Allowing excessive short-term trading in One Group funds by a hedge-fund manager that was inconsistent with the terms of the funds prospectuses and that was potentially harmful to the funds; 2. Failing to disclose to the One Group Board of Trustees or to shareholders the conflict of interest created when Respondents entered into a market-timing arrangement with a hedge-fund manager that was potentially harmful to One Group, but that would increase BOIAs advisory fees and potentially attract additional business; 3. Failing to charge the hedge-fund manager redemption fees as required by the international funds prospectuses when other investors were charged the redemption fees; 4. Having no written procedures in place to prevent the nonpublic disclosure of One Group portfolio holdings and improperly providing confidential portfolio holdings to the hedge-fund manager when shareholders were not provided with or otherwise privy to the same information; 5. Causing One Group funds, without the knowledge of the funds trustees, to participate in joint transactions, raising a conflict of interest in violation of the Investment Company Act (from the SEC Order, June 29, 2004, p. 2). In the settlement agreement, Bank One agreed that Banc One Investment Advisors would pay $10 million in restitution, as well as pay $40 million as a penalty. The entire amount of $50 million would be paid to shareholders. It would be placed in an escrow account to be distributed to eligible shareholders through a plan created by an independent consultant and approved by the SEC and One Group Board of Trustees. In addition, Banc One Investment Advisors agreed to reduce advisory fees by $8 million per year for five years. In addition, BOIA would not raise advisory fees for five years. Mark Beeson, former President and Chief Executive Officer of the One Group Mutual Funds unit of Bank One, was banned for two years from the mutual fund industry and fined $100,000 for his role in improper short-term trading. Beeson neither admitted nor denied any wrongdoing.

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The Aftermath
After the settlement, David J. Kundert, Chairman and CEO of Banc One Investment Advisors, remarked, Soon after we first learned of these investigations, we committed to cooperate with regulators, make restitution to shareholders, and review and change our policies as appropriate. The monetary and governance actions outlined in these agreements build upon the controls and policies we initiated last fall to fulfill that commitment. Strong procedures are now in place to further protect the interests of our mutual fund shareholders and prevent a recurrence of similar issues in the future (CT News Archive, June 29, 2004). Peter C. Marshall, Chairman of the One Group Board of Trustees, explained the settlement in an August 2004 letter to One Group Mutual Fund shareholders. The prospectus that was enclosed with Marshalls letter outlined the steps that the bank would take to implement the settlement. The One Group Mutual Funds Supplement that accompanied the letter informed investors that they would receive a proportionate share of the money lost from market-timing, as well as advisory fees paid by the affected funds during the market-timing. Payment was expected to be made in 2005. The final lines of the enclosed prospectus cautions shareholders that It is possible, although not likely, that these matters and/or related developments may result in increased Fund redemptions and reduced sales of Fund shares, which could result in increased costs and expenses or otherwise adversely affect the Funds. The outcomes of the settlements and reforms implemented by Bank One, now J.P. Morgan Chase and Co., remained to be seen. Would Dimons strategy of ethical behavior, transparency, and communication restore confidence in the funds? Or would fund redemptions increase and sales of shares decrease? What would be the effect of the investigations and resulting settlements on the industry? What reforms would be adopted by, or imposed on, the mutual fund industry?

Acknowledgments
The author gratefully acknowledges the support and assistance of Beth Dowie, Vice President of Support Services, J.P. Morgan Chase & Co. She also thanks Andrew Inkpen, Director of the Thunderbird Case Clearinghouse, for financial support of the project; Helen Grassbaugh, Administrative Assistant for the Thunderbird Case Clearinghouse; and Georgia Lessard, Documentation Specialist. She also appreciates the patience and insights of Robert E. Grosse, professor of international business at Thunderbird.

References
Arizona Republic. Mutual Fund Woes Blamed on Stale Pricing, November 11, 2003, D7. Atlas, Riva D. Justice Obstruction Charges Called Possible in Fund Case, New York Times, October 16, 2003. CT News Archive. Banc One Investment Advisors Confirms Mutual Funds Settlement Agreements, June 29, 2004. Brewster, Deborah. Banc One Pays $50m on Market Timing, Financial Times, June 30, 2004, p. 18. Carey, Susan. Fund Probe Spurs Bank One Exits, Wall Street Journal, October 16, 2003. Dimon, Jamie. Internal Message, September 9, 2003. Dimon, Jamie. Internal Message, October 15, 2003.
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Gordon, Marcy. Congress Joins Probe of Mutual Fund Scam, AOL News November 3, 2003. http:/ /aolsvc.news.aol.com/news/ Johnson, Carrie. Bank One Expecting Regulatory Actions: Firm was Named Early in Mutual Funds Probe, Washington Post, November 27, 2003. Kundert, Dave. Bank One Internal Message to Employees, November 26, 2003. Lauricella, Tom. Probe Signals Shake-Up for Mutual Fund Industry, Wall Street Journal, October 20, 2003. Lauricella, Tom. Bank One Unit Agrees to Pay $90 Million Over Fund Trades. Wall Street Journal, June 30, 2004, pp. A1, A5. Manor, Robert. Bank One Exec Quits over Fund Trading, Chicago Tribune, October 16, 2003. Marshall, Peter C. Letter to Bank One Mutual Fund Customers, October 10, 2003. Marshall, Peter C. Letter to Bank One Mutual Fund Customers July 8, 2004. McGeehan, Patrick. Mutual Fund Industry Booms Despite Scandal, The New York Times, January 11, 2004. One Group Mutual Funds Supplement, dated July 8, 2004, to all One Group Mutual Fund prospectuses dated on or after February 28, 2004. Quinn, Jane Bryant. Mutual Funds Greed Machine, Newsweek, November 24, 2003, p. 45. Shipman, John. Bank Ones Fund Unit Told to Expect Enforcement Action, Dow Jones Newswire, November 26, 2003. Siegel, Tara. Bank One CEO Reiterates Restitution for Hurt Fund Holders, Dow Jones Newswire, October 22, 2003. Stempel, Jonathan. Bank One Expects Enforcement Action, Reuters News Service, November 26, 2003. Vickers, Marcia. Dynasty in Distress, Business Week, February 9, 2004, pp. 63-70. Waggoner, John, Christine Dugas, and Thomas A. Fogarty. SEC Wades through a Mutual-Fund Cesspool, The Arizona Republic, November 4, 2003, pp. D1, D3. Wall Street Journal Online. JPMorgan Chase, Bank One Complete Merger, Press Release July 1, 2004, http://online.wsj.com/article/0,,PR_CO_20040701_000009,00.html. Wall Street Journal Online. Securities and Exchange Commission Order to Banc One Investment Advisors Corporation and Mark A. Beeson, June 29, 2004.

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