All these layoffs could even make a CEO nervous, which is probably why the U.S. Securities and Exchange Commission took the trouble to remind all of them not to do anything stupid.

On December 2, SEC director Lori A. Richards sent an open letter to all SEC-registered companies specificially to say that no matter how difficult times get, there's no excuse or tolerance for shortcuts.

While many firms are considering reductions and cost-cutting measures, we remind you of your firm's legal obligation to maintain an adequate compliance program reasonably designed to achieve compliance with the law. As SEC Chairman Cox noted recently, "[E]xperience has taught us again and again that giving short shrift to regulatory compliance subjects a company's investors, employees, management, directors, and every other stakeholder to unacceptable risks….[C]ompliance programs have made huge strides in recent years in becoming more formalized and more robust…. Now more than ever, companies need to take a long-term view on compliance and realize that their fiduciary responsibility requires a constant commitment to investors. That means sustaining their support for compliance during this market turmoil, and beyond it as well."

Translation: With thousands of people losing their jobs every day, don't even think about it. Full letter after the jump. [CNS]

How long has Variety's Ben Fritz pounded on the idea that Sumner Redstone's Midway Games was a full-throttle loser? At least since June 30, 2005-- the day Redstone sent a fax that attempted to contradict Fritz's naysaying coverage. Apparently, Redstone was thoroughly irked -- enough to misspell "Ben Fritz" as "Den Fitz." You can find Fritz's article on the Midway fire sale here.

First off: Can you believe what former TYCO CEO Dennis Kozlowski looks like? He's straight from Central Casting as a fatcat-turned-jailbird. Secondly: As Silicon Alley Insider's Caroline Wexler points out, "Why the jailers would agree to let him appear (on Fox Business) is beyond us."

However, he may (may - not putting money on that, no pun intended) have a point when he says his actions don't really register when you look at Lehman Brothers, Bear Stearns and AIG: "Tyco is still a viable company, still alive and kicking. Bear Sterns is under, Lehman Brothers is under. Merrill Lynch had to be acquired. There are all kinds of banks going under right now."

Still, it's hard to feel too badly when he says stuff like this: "I sit here and I read about a $150 billion bailout of AIG, I compare it to a $6,000 shower curtain. It's hard to reconcile the two."

True. That's because NO ONE IS SUGGESTING THEY'RE THE SAME THING. It's not like his gold-laced shower curtain wasn't obnoxious, but it didn't even came close to being the extent of his sins against Tyco Intl.; he was convicted of misappropriating more than $400 million in corporate funds. Granted, an AIG bailout could support 37 Kozlowskis in the lifestyle to which they were accustomed, but let's face it: That's still pretty gross. [Fox Business]

Imagine: Sumner Redstone could satisfy the banks and annoy the hell out of his daughter Shari! That's the scenario Peter Lauria suggests as a possible solution to Redstone's ongoing talks to refinance $1.6 billion in debt. While Redstone gave no specifics in yesterday's earning all beyond pointing out that holding company National Amusements "is also a substantial theater operation that owns valuable real estate holdings across the country," Lauria's sources say that could refer to several scenarios, including "selling some theater operations or selling a stake in the holding company itself. Either one is likely to re-ignite simmering tensions between Redstone and his daughter Shari, who is president of National Amusements." Or? The land could be used as "collateral in talks with the banks." [NYP]

Could Disney buy Electronic Arts? Martin Peers suggests that such a purchase could look awfully yummy, given EA's sinking stock price and a $7.2 billion valuation  -- a 62% discount off its $19 billion profile of a few years ago -- and strong sales on titles like "Spore" and "Rock Band 2." Writes Peers, “Any entertainment company could be interested in EA, given continued growth in videogame sales, the potential for cross-fertilization with TV and film storylines and advertisers’ interest in buying space in games. Disney makes the most sense. EA’s biggest assets include its sports games, such as Madden NFL, which would fit with Disney’s ESPN cable network. Disney could also save at least part of the roughly $200 million it spends annually to develop its own games.” [Heard on the Street]

RELATED

• Games publisher THQ closes five studios [Kotaku]
• An EA/Disney deal "unlikely in the current market" [Digital Daily]

Every day brings another article head-gazing/navel-scratching around the theme Will Hollywood Flail or Thrive in the Depression? However, there is a small, flickering light at the end of the tunnel: Eric Savitz points out that Stifel Nicolaus analyst Scott Devitt has "upped his rating on Netflix (NFLX) to Buy from Hold, setting a $25 target price." Writes Devitt, “In the current economy, Netflix value-oriented offering stands out to us as a compelling alternative to more expensive entertainment alternatives. Due to its relative value, we believe the Netflix existing subscriber base may remain more stable in the downturn and new subscribers could improve once the initial shock of the past few months subsides.” Yay? Netflix stock has nonetheless been in decline all day; at this writing it's down 3.6%, to $18.27. [Barron's]

RELATED
Laid-off librarian cancels Netflix subscription [AP]
In tough times, what will you pay for an hour of fun? [Time]
Will Microsoft buy Netflix? [Wired I Epicenter]

It's been a hell of a week for Sumner Redstone and, according to Charlie Gasparino, it only looks to get worse. Renegotiations for National Amusements' $1.6 billion bank debt, half of which must be paid by the end of the year, are being described as "difficult" and a Gasparino source thinks the talks will fall through. And, despite Redstone's protestations, a CBS/Viacom sale "is among the alternatives being weighed by the Redstone's advisers." However, his advisers would first look to sell other NA assets. These include a 1,500-screen cinema chain and Midway Games, which currently trades at 65 cents per share. [CNBC]

Geraldine Fabrikant writes: "On Monday, National Amusements, the privately held company that is run by Ms. Redstone, was forced to sell $233 million worth of stock in Viacom and CBS. On Tuesday, the company issued a statement saying that the sale of shares was prompted by market conditions and not by the operation and expansion of the company’s theater business. An article in The Wall Street Journal on Monday said that National Amusements had sold the shares to back a $1.6 billion loan that was used in part to help expand its movie theater chain. While the statement was not attributed to Mr. Redstone, Ms. Redstone apparently felt it was necessary to issue a statement saying that was not the case. Ms. Redstone declined to comment." [New York Times, via Huffington Post]

Don't look to Asia for a bailout; the roiling of Wall Street has Asia wondering just why they invested trillions in the U.S. in the first place. Writes Keith Bradsher, "Asia’s savings have, in essence, bankrolled American spending for decades, and an Asian loss of confidence in American financial institutions and assets would have dire consequences for both the United States government and American taxpayers." Bradsher quotes a Hong Kong homemaker waiting in line to close her A.I.G. investment account (“I do not believe in U.S. financial institutions anymore; I don’t think any U.S. bank is safe anymore.”) and Thomas Lam, senior treasury economist at United Overseas Bank in Singapore. “All these top executives, Indonesians and others, started asking, ‘What do they really do?’ They bought because the next company did.” [New York Times]