 At the onset of the litigation SEC and Bank of America Corporation filed with the Court a proposed settlement for $33 million.Grundfest's affidavit supported the Settlement Agreement then before the Court, which was eventually rejected.In September 2019, Grundfest put forth a solution to deal with the impact of Cyan, Inc. v. Beaver County Employees Retirement Fund which ruled that plaintiffs could bring Section 11 suits in state courts and not just in federal courts, in which he suggested that company's could add federal forum provisions (FFPs) to their charter documents to the effect that plaintiffs could only bring Section 11 Suits in federal court.