Whistleblower Provisions Regulation - Comment Letter - Financial Services Roundtable - 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

CFTC Whistleblower Provisions
February 4, 2011

From the comment letter:

"While the Roundtable supports the Commission’s efforts to encourage those with information about possible corporate wrongdoing to make that information known, the Roundtable is concerned that:

  • the Proposed Rules fail to place sufficient reliance on the effectiveness of the internal compliance procedures that so many companies, including our members, have established;
  • the Proposed Rules will do damage to those efforts as employees and others with knowledge about possible violations of applicable laws, rules and regulations (referred to herein as “applicable law”) avoid even the most highly effective internal policies in order to preserve and protect the possibility, no matter how remote, of receiving large cash awards; and
  • the Proposed Rules are similar to rules proposed recently by the SEC, but there are some significant differences and inconsistent terms that the CFTC and SEC should harmonize, so that companies will not be subject to potentially inconsistent requirements or otherwise led to assume inadvertently that they are in compliance with both regimes when, in fact, they are not fully compliant with one or the other."

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