Whistleblower Provisions Regulation - Comment Letter - Covington & Burling - February 18, 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

SEC Whistleblower Provisions
February 18, 2011

Covington & Burling LLP represents the following organizations:

  • Apache Corp.
  • Cardinal Health Inc.
  • The Goodyear Tire & Rubber Co.
  • Hewlett-Packard Co.
  • Merck & Co. Inc.
  • Microsoft Corp.
  • Newmont Mining Corp.
  • Procter & Gamble Co.
  • TRW Automotive Holdings Corp. and
  • United Technologies Corp.

A summary of the comment letter:

  1. "Congress has granted the Commission broad authority to implement the whistleblower provisions of Section 21F."
  2. "The Commission has authority to make utilization of effective internal reporting procedures a prerequisite for whistleblower recovery."


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