Whistleblower Provisions Regulation - Comment Letter - American Institute of Certified Public Accountants - February 4, 2011

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Gavel.png FINAL RULE: This page refers to the proposed rulemaking on whistleblower provisions. The CFTC final rule was issued at its August 4, 2011 open meeting. The SEC final rule was issued at its May 25, 2011 open meeting.
Dodd-Frank Timeline, Whistleblower Provisions, CFTC
Final Rule Issue Effective Date Proposed Amendment
August 4, 2011 October 24, 2011 August 30, 2016

Whistleblower Provisions
February 4, 2011

From the comment letter:

  • "The AICPA urges that the final rules make it clear that CPAs and personnel of CPA firms that provide audit services to entities subject to CFTC jurisdiction are not eligible for whistleblowers awards."
  • "[The] free flow of communication could be chilled if the CFTC creates a monetary incentive for individuals associated with CPA firms to disclose information received in the course of an audit or other engagement."
  • "The AICPA is concerned that the 90-day “grace period” for employees and potential “credit” for first utilizing employer compliance processes will not sufficiently encourage potential whistleblowers to report first through a company’s internal reporting process."


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