Whistleblower Provisions Regulation - White Paper - McGuireWoods - The Rules for Whistleblowers:Significant Aspects of the SEC’s Whistleblower Incentives and Protection Program - May 2011

From Markets Reform Wiki
Jump to navigation Jump to search
Dodd-Frank Timeline, Whistleblower Provisions, CFTC
Final Rule Issue Effective Date Proposed Amendment
August 4, 2011 October 24, 2011 August 30, 2016
Dodd-Frank Timeline, Whistleblower Provisions of Secton 21F of the Securities Exchange Act of 1934
Comment Deadline Final Rule Issue Effective Date
December 17, 2010 June 13, 2011 August 12, 2011

May 2011

This paper was prepared by Kurt E. Wolfe of McGuireWoods LLC. "Key Takeaways" from the paper:

"Regulated entities should develop, improve and promote compliance and reporting policies and procedures. This might include reviewing and updating your internal whistleblower programs, putting in place a dedicated team to review internal complaints, and establishing procedures for handling tips."

"In devising and advertising your legal, audit, or compliance programs, companies should stress three issues that will likely be essential to attracting internal reporting:

  1. The SEC will award higher bounties for whistleblowers who report internally before submitting a tip to the SEC.
  2. Whistleblowers who report internally are eligible for a whistleblower bounty from the SEC whether or not they submit a tip to the SEC, if the company self-reports. The bounty will be based not just on the whistleblower’s knowledge, but on all information the company submits to the SEC.
  3. Both the company and the whistleblower rules have strong antiretaliation policies designed to protect whistleblowers who come forward with evidence of a violation."


<references />

MarketsReformWiki Sponsors

RSM US LLP ADM Investor Services Cinnober Fidessa