In its recent comprehensive bank examination, the First National Bank of Sleepy Hollow received a grade of “needs to improve” for its compliance program. The Comptroller of the Currency noted numerous weaknesses in the bank’s system of internal controls over money laundering and fair lending practices. The report of examination did not point to any specific instances of violations, and the bank’s managers disagree with the regulators’ opinion: They think the compliance program is robust and effective. The bank is about to “go public” by issuing securities registered with the SEC. The draft registration statement states that “the Bank’s systems of internal controls are well designed and scalable to account for future anticipated growth.” As outside securities counsel, you are aware of the “needs to improve” rating. You are also aware that the bank is legally prohibited from disclosing information about its examination reports. Your client and its investment bank insist that the statement about internal controls is essential in order to assure the success of the public offering. What do you do?