📜 Post with us on Reddit
📝 Create a new article
🏭 Create a company page
🇬🇧 - in English
🇫🇷 - en Français (FR)
🇵🇹 - em Português (PT)
🇩🇪 - in Deutsch (DE)
🇯🇵 - 日本語で (JA)
Sponsored articles

You can edit almost every page by Creating an account. Otherwise, see the FAQ.

SEC Whistleblower Program

From EverybodyWiki Bios & Wiki



The SEC Whistleblower Program[edit]

On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law. Among its many provisions, Dodd-Frank directed the Securities and Exchange Commission (SEC or Commission) to create a new whistleblower program to provide eligible whistleblowers with significant monetary awards, employment protections and the ability to report anonymously.[1] The implementing rules became effective in August 2011 and, during the ensuing years, has been responsible for more than $1 billion in sanctions collected from bad actors and substantial monetary awards paid to dozens of whistleblowers.[2][3]

Origins[edit]

Following the 2008 financial crisis, legislators and regulators alike debated how to curb the cycle of corporate corruption that had plagued the financial marketplace. As schemes grew more complex, law enforcement realized that they required early actionable intelligence to better detect and deter large-scale securities violations.[4]  The idea of a new whistleblower program at the SEC was first conceived by SEC Chairman Mary Schapiro, who announced during her confirmation hearing the desire to explore the potential of such a program. After being confirmed, she appointed a small working group to assess the viability of a new whistleblower program that included Jordan Thomas, then an Assistant Director in the Enforcement Division. Ultimately, the working group recommended the establishment of the SEC Whistleblower Program, drafted proposed legislation and briefed members of the Commission and Congress on the program’s potential.        

In 2009, Senator Barney Frank and Representative Chris Dodd proposed the Dodd-Frank Wall Street Reform and Consumer Protection Act, the most sweeping financial reform effort since the Great Depression. Section 922 of the Dodd-Frank Act charged the SEC with the creation of a whistleblower program to protect and reward individuals who provide the agency with high-quality tips that lead to successful enforcement actions.[5] This aspect of the groundbreaking law closely mirrored the legislation drafted by Chairman Schapiro’s working group and proposed by the Commission.    

In late 2010, the SEC released proposed rules governing the SEC whistleblower program and requested public comments.[6] When the comment period closed on December 17, 2010, the Commission had received 240 comments and 1300 form letters on areas including internal reporting, eligibility of attorneys, auditors and compliance professionals, retaliation protections and awards for culpable individuals, among others.[7] The Commission reviewed the public commentary and revised some elements of the governing rules, before releasing final rules for the program, which became effective on August 12, 2011.[8]

To administer the whistleblower program, the SEC established the Office of the Whistleblower. While the Division of Enforcement investigates and prosecutes possible securities violations, the primary function of the Office of the Whistleblower is to administer the whistleblower awards process, making recommendations on whether claimants have satisfied the eligibility requirements to receive an award and the appropriate size of any awards. The first Chief of the Office of the Whistleblower was Sean McKessy.[9] The current Chief Jane Norberg, the first woman to hold this senior position, was appointed on September 28, 2016.[10]  

Pillars of the SEC whistleblower program[edit]

Anonymous reporting[edit]

Recognizing the real fear of retaliation–19% of financial services employees in the US and UK believe their employers would retaliate if they reported wrongdoing[11]—in crafting its whistleblower program, the SEC enables whistleblowers to file their reports anonymously if the whistleblower works with an attorney.[12][13] The attorney will verify the identity of the whistleblower before any information is submitted to the SEC[14]; serve as an intermediary between the SEC and whistleblower during any investigation and related enforcement action; and, in the case of a successful enforcement action, advocate for the highest potential monetary award.[15][16]

Employment protections[edit]

The program also maintains powerful employment protections.[17][18] Employers may not, directly or indirectly, discharge, demote, suspend, threaten, harass, or in any way discriminate against whistleblowers who: provide information to the SEC; initiate, testify in, or assist in an SEC investigation or related enforcement action; or make any disclosures required or protected by law.[19][20] The SEC first exercised its new anti-retaliation authority in 2015, when it issued the maximum possible award to a whistleblower who suffered retaliation for reporting a hedge fund’s prohibited transactions to the SEC.[21][22][23][24][25]

Importantly, the SEC’s whistleblower protections exist regardless of whether or not the alleged securities violations are proven or lead to a successful enforcement action, as long as whistleblowers reasonably believe that their tips relate to a possible violation of the federal securities laws.[26] In fact, in September 2016, the SEC announced that International Game Technology (IGT) had been fined $500,000 for terminating an SEC whistleblower even though the whistleblower’s claims ultimately proved false.[27]

If whistleblowers are subjected to retaliation in violation of the law, they have the right to immediately sue their employers in federal court, without having to exhaust the administrative process before filing. The types of remedies available include reinstatement with equivalent seniority, double back pay with interest, attorney fees, and reimbursement of other litigation related expenses. Whistleblowers have six years from the retaliatory conduct, or three years from when the employee knew or reasonably should have known of the retaliatory conduct, to file a claim—if it is not more than 10 years after the violation occurred.[28][29]

Monetary awards

Under the rules of the SEC Whistleblower Program, the SEC may, at its discretion, award eligible whistleblowers between 10-30% of monetary sanctions collected in a successful enforcement action where the sanctions exceed $1 million.[30][31] Given that the SEC levies billions of dollars each year in monetary sanctions, SEC whistleblowers may be eligible for large monetary awards.[32][33]

In exercising its discretion to determine the precise amount of an award, the Commission considers a variety of factors. Certain criteria may increase an award, such as the significance of the information provided by the whistleblower, the assistance provided by the whistleblower, the law enforcement interest in making an award and the participation of the whistleblower in internal reporting systems.

Other factors may decrease an award, such as the culpability of the whistleblower, unreasonable reporting delay and interference with internal compliance and reporting systems.[34][35][36]

Whistleblower awards are paid from a replenishing investor protection fund established by Congress that is financed entirely by penalties levied by the SEC in enforcement actions.[37] Importantly, no money is withheld from injured investors or American taxpayers to fund whistleblower bounties. At the close of FY2016, the fund had a balance in excess of $368 million.[38]

Awards issued each year

Given that SEC investigations take approximately two to four years to complete, there were no awards made in the Program’s first year of operation.[39]

The first SEC whistleblower award was made on August 21, 2012 to a whistleblower who provided documents and information relating to an ongoing multi-million dollar fraud. The whistleblower received $50,000, which represented 30 percent of the amount the Commission had collected at the end of the fiscal year.[40]

Four awards were made in Fiscal Year 2013, which totaled nearly $15 million.[41] In June 2013, the SEC made an award to three whistleblowers whose information helped to shut down a sham hedge fund. Then, in October, the SEC awarded a whistleblower more than $14 million.[42]

In Fiscal Year 2014, the Commission issued awards to 9 whistleblowers, with actual payouts during the year approaching $2 million.[43]

In Fiscal Year 2015, the Commission paid more than $37 million out of the Investor Protection Fund to eight whistleblowers.[44]

Fiscal Year 2016 proved to be record-breaking, with the SEC awarding $57 million in whistleblower awards, more than the total paid in all years combined.  After five full years of reporting, the Commission had paid more than $111 million to 34 whistleblowers.[45]

In Fiscal Year 2017, the SEC ordered whistleblower awards totaling nearly $50 million to 12 individuals.  Since the agency issued its first award in 2012 through the end of September 2017, the program has awarded approximately $160 million in whistleblower awards to 46 individuals.[46]

Notable awards

In 2014, the SEC announced that it would award more than $30 million to a whistleblower outside the U.S. who provided information about an ongoing fraud. At the time of issue, the award was the largest award to date and the fourth award to an individual living in a foreign country. The award may have been higher, but for an “unreasonable delay” in reporting the violations to the Commission, leading to continued suffering by investors.[47][48]

Also that year, the SEC announced an award of more than $300,000–the first to an employee in an audit or compliance function–who filed a submission with the SEC after reporting internally and the company failed to take action.[49][50]

In 2015, the SEC made a number of landmark whistleblower awards, including the first award to a former company officer.[51][52] While officers are typically ineligible for SEC awards, the rules provide an exception if the officer tips the agency more than 120 days after other responsible compliance personnel possessed the information and failed to address the allegations.[53] That year also marked the first action involving the SEC’s new anti-retaliation authority established under Dodd-Frank. In a high-profile action against Paradigm Capital Management, the agency issued the maximum possible award to a whistleblower who suffered retaliation for reporting a hedge fund’s prohibited transactions to the SEC.[54][55][56][57][58]

In its most active year since the program was established, in 2016, the SEC granted more than five awards in excess of $4 million, most of which were issued to current or former employees of the entities on which they reported.[59]

Underscoring that timing matters in reporting violations of the securities laws to the SEC, in connection with a 2017 action, the SEC awarded more than $7 million to three whistleblowers.[60] The whistleblower whose tip launched the SEC’s investigation was granted more than $4 million, while two other whistleblowers who later provided new information to support the SEC’s investigation will split more than $3 million.

The SEC has announced numerous precedential awards in the pipeline.  In 2017, the Commission announced a $8.25 million settlement with Orthofix International, which investigation was spurred by two analysts who spotted an irregularity while reviewing earnings calls and reports. Both men could receive at least $2.5 million.[61]

In July 2017, it was announced that two SEC whistleblowers would share a record $61 million award for their contributions to an action involving JPMorgan Chase & Co. which, in December 2015, agreed to pay $307 million in penalties, with $267 million going to the SEC and $40 million to the Commodity Futures Trading Commission.[62][63][64]

Also in the pipeline is a yet-to-be-announced whistleblower award in connection with the 2016 announcement that Bank of America Corp’s Merrill Lynch brokerage unit will pay $415 million and admit to wrongdoing to settle charges in the largest customer protection settlement in SEC history.[65][66][67]

Common securities violations reported[edit]

Corporate disclosures and financials[edit]

Since inception, on average, 17.3% of all SEC whistleblower tips have involved corporate disclosure and financials.[68] This type of securities violation often relates to false or misleading financial statements that have been filed with the SEC in either a company’s registration statement, prospectus, or as part of any other of the company’s required filings under the Exchange Act.[69]

Offering fraud[edit]

Since inception, on average, 16% of all SEC whistleblower tips have involved offering fraud.[70] This type of securities violation generally occurs when an individual, or group of individuals, makes misrepresentations and/or omissions of material fact to potential investors in a new company.[71]

Market manipulation[edit]

Since inception, on average, 13.6% of all SEC whistleblower tips have involved market manipulation.[72] This type of securities violation relates to the interference with the free and fair operation of the market by engaging in conduct that creates an artificial price or maintains an artificial price for a security.[73]

Insider trading[edit]

Since inception, on average, 6.6% of all SEC whistleblower tips have involved insider trading.[74] This type of securities violation relates to the buying or selling of a corporate security while in possession of material information about a corporation that is not known to the public.[75]

Trading and pricing[edit]

Since inception, on average, 5.2% of all SEC whistleblower tips have involved trading and pricing.[76] This type of securities violation involves any number of trading techniques that are illegal under the securities laws including, but not limited to:  market timing, late trading, marking the close, front running, pooling, freeriding, stock parking, naked shorting, and churning.[77]

Foreign corrupt practices act[edit]

Since inception, on average, 4.9% of all SEC whistleblower tips have involved FCPA violations.[78] This type of securities violation prohibits the offer, payment, or promise to pay money or anything of value—i.e., a bribe—to any foreign official in an effort to win or retain business from that foreign official’s government.[79]

Market events[edit]

Since inception, on average, 3.4% of all SEC whistleblower tips have involved market events.[80] This type of securities violation refers to disruptions or aberrations in the securities markets, such as an unexpected interruption in trading on a securities exchange, a liquidity crisis or a “flash crash.”[81]

Unregistered securities offerings[edit]

Since inception, on average, 3.3% of all SEC whistleblower tips have involved unregistered securities offerings.[82] With limited exception, offerings of securities in the U.S. must be registered with the SEC. An offering that is not registered, or that fails to meet/adhere to the requirements for exemption, constitutes a violation.[83]

Municipal securities and public pensions[edit]

Since inception, on average, 1.5% of all SEC whistleblower tips have involved municipal securities and public pensions.[84] Municipal securities are debt securities issued by state and local governments in the United States, and are generally used to fund items such as infrastructure, schools, libraries, general municipal expenditures.  As with any security, securities laws prohibit any person from making a false or misleading statement of material fact, or omitting to state any material fact, in connection with the offer, purchase, or sale of any municipal security.[85]

Emerging issues[edit]

Internal reporting[edit]

In developing the SEC Whistleblower Program, one of the most hotly debated issues was whether individuals should be required to report possible securities violations to their employers in the first instance.[86] During the comment period, numerous commercial organizations and business groups argued that without such a requirement, the SEC would effectively undermine corporate compliance programs.[87] After considering these comments, the SEC determined that requiring internal reporting may dissuade some prospective whistleblowers. So rather than require internal reporting, the Commission opted to incentivize it by providing in the SEC Whistleblower Rules that "a whistleblower's voluntary participation in an entity's internal compliance and reporting systems is a factor that can increase the amount of an award."[88]

The question later emerged if an employee reported possible securities violations internally would the employee have the same employment protections available to those who reported directly to the SEC. Despite the fact that many employers and business groups lobbied heavily to require internal reporting during the public comment period for the SEC Whistleblower Rules, some employers have taken the position in subsequent litigation that internal reporting is not protected conduct and federal appellate courts have disagreed on the issue.[89] In August 2015, after filing several amicus briefs in federal district and appellate courts around the country, the SEC issued interpretive guidance reiterating that whistleblowers were entitled to anti-retaliation protections, even if they did not report these possible violations to the Commission.[90] As a result, on June 26, 2017, the U.S. Supreme Court granted certiorari in Digital Realty Trust Inc. v. Somers to resolve whether the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 protects whistleblowers who have not reported possible securities violations to the Securities and Exchange Commission.[91]

Secrecy agreements[edit]

Another significant issue that has surfaced in connection with the SEC Whistleblower Program is the use of nondisclosure agreements to prevent employees from reporting possible securities violations or otherwise cooperating with federal law enforcement and regulatory authorities. After the program was established and the probability of detection increased, some companies discouraged external reporting with a variety of employment, severance and settlement agreements.[92][93]

In 2014, a coalition led by SEC Whistleblower Advocate Jordan Thomas and the Government Accountability Project petitioned the SEC for rulemaking to clarify its position on the reach of the program’s retaliation protections and the proliferation of secrecy agreements designed to silence or otherwise limit employees' rights and protections as SEC whistleblowers.[94][95] The Commission has responded to this petition by aggressively prosecuting numerous prominent companies for engaging in these illegal practices. And, in 2016, the Commission announced that it deems illegal any limitation on an employee’s ' ability to disclose confidential trade secret information to the SEC, if the employee wants to make disclosure in pursuit of whistleblower claims. In a Risk Alert, the Commission warned of its broad review of compliance manuals, codes of ethics, employment agreements and severance agreements, for language that runs afoul of disclosure rules for whistleblowers.[96] Critics said these agreements were illegal and the SEC agrees.[97][98]

According to the FY 2016 Annual Report of the Office of the Whistleblower, 65% of whistleblowers are insiders employed by the company on which they report and the overwhelming majority of these employees – 80% -- raised their concerns internally first.[99]

Geographical reach of the SEC whistleblower program[edit]

To participate in the SEC Whistleblower Program, whistleblowers must complete the Tips, Complaints and Referral form, specifically SEC Form-TCR and submit it by mail, fax or through the Commission’s online portal.[100][101] As part of a signed submission, a whistleblower acknowledges the truth of the submission’s declarations under the penalty of perjury.

References[edit]

  1. ↑ "Section 922: Dodd-Frank SEC Whistleblower Protections". Report SEC Fraud. Retrieved 2018-01-09.
  2. ↑ "2016 Annual Report to Congress on the Dodd-Frank Whistleblower Program" (PDF).
  3. ↑ "Office of the Whistleblower Regulation 21F" (PDF).
  4. ↑ "Point-Counterpoint: Dodd-Frank Whistleblower Rules - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  5. ↑ "Increasing Regulatory Enforcement and Remedies" (PDF).
  6. ↑ "Proposed Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934" (PDF).
  7. ↑ "Comments on File No. s7-33-10". www.sec.gov. Retrieved 2018-01-09.
  8. ↑ "Implementation of the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934" (PDF).
  9. ↑ "Sean McKessy Named Head of Whistleblower Office; 2011-47; February 18, 2011". www.sec.gov. Retrieved 2018-01-09.
  10. ↑ "Norberg Named As New SEC Whistleblower Chief - Law360". www.law360.com. Retrieved 2018-01-09.
  11. ↑ "Historic Survey of Financial Services Professionals Reveals Widespread Disregard for Ethics, Alarming Use of Secrecy Policies to Silence Employees". www.labaton.com. Retrieved 2018-01-09.
  12. ↑ "Anonymous Reporting - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  13. ↑ "Reporting Without Regrets—The SEC Whistleblower Program Handbook" (PDF). Labaton Sucharow. May 2017.
  14. ↑ "Regulation 21F, Rule 7(b)" (PDF).
  15. ↑ "Anonymous Reporting - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  16. ↑ "Reporting Without Regrets—The SEC Whistleblower Program Handbook" (PDF). Labaton Sucharow. May 2017.
  17. ↑ "Reporting Without Regrets—The SEC Whistleblower Program Handbook" (PDF). Labaton Sucharow. May 2017.
  18. ↑ "Employment Protections - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  19. ↑ "Section 922: Dodd-Frank SEC Whistleblower Protections". Report SEC Fraud. Retrieved 2018-01-09.
  20. ↑ "Regulations 21F, Rule 2(b)" (PDF).
  21. ↑ "SEC accuses firm of whistleblower retaliation". USA TODAY. Retrieved 2018-01-09.
  22. ↑ "SEC.gov | SEC Charges Hedge Fund Adviser With Conducting Conflicted Transactions and Retaliating Against Whistleblower". www.sec.gov. Retrieved 2018-01-09.
  23. ↑ "SEC.gov | SEC Announces Award to Whistleblower in First Retaliation Case". www.sec.gov. Retrieved 2018-01-09.
  24. ↑ "Hedge fund settles SEC case over whistleblower retaliation". Reuters. 16 June 2014. Retrieved 2018-01-09.
  25. ↑ "Regulation 21F, Rule 2(b)(2)" (PDF).
  26. ↑ "Regulation 21F, Rule 2(b)(1)(iii)" (PDF).
  27. ↑ "Gaming Concern That Fired Whistle-Blower to Pay $500K". www.bna.com. Retrieved 2018-01-09.
  28. ↑ "Reporting Without Regrets—The SEC Whistleblower Program Handbook" (PDF). Labaton Sucharow. May 2017.
  29. ↑ "Employment Protections - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  30. ↑ "Reporting Without Regrets—The SEC Whistleblower Program Handbook" (PDF). Labaton Sucharow. May 2017.
  31. ↑ "Monetary Awards - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  32. ↑ "SEC Sanctions Database - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  33. ↑ "SEC.gov | SEC Announces Enforcement Results for FY 2016". www.sec.gov. Retrieved 2018-01-09.
  34. ↑ "Monetary Awards - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  35. ↑ "Section 922: Dodd-Frank SEC Whistleblower Protections". Report SEC Fraud. Retrieved 2018-01-09.
  36. ↑ "Regulation 21F, Rule 6" (PDF).
  37. ↑ "Section 922: Dodd-Frank SEC Whistleblower Protections". Report SEC Fraud. Retrieved 2018-01-09.
  38. ↑ "Agency Financial Report Fiscal Year 2016" (PDF). November 2016.
  39. ↑ "Reporting Without Regrets—The SEC Whistleblower Program Handbook" (PDF). Labaton Sucharow. May 2017.
  40. ↑ "SEC.gov | SEC Issues First Whistleblower Program Award". www.sec.gov. Retrieved 2018-01-09.
  41. ↑ Pavlo, Walter. "What The SEC Whistleblower Report Means For Companies". Forbes. Retrieved 2018-01-09.
  42. ↑ Pavlo, Walter. "The Anonymous SEC Whistleblower Award Of $14M Is A Game Changer". Forbes. Retrieved 2018-01-09.
  43. ↑ "2014 Annual Report to Congress on the Dodd-Frank Whistleblower Program" (PDF).
  44. ↑ "2015 Annual Report to Congress on the Dodd-Frank Whistleblower Program" (PDF).
  45. ↑ "SEC Whistleblower Program Records Best Year - Corporate Crime Reporter". Corporate Crime Reporter. 2016-11-22. Retrieved 2018-01-09.
  46. ↑ "2017 Annual Report of the Dodd-Frank Whistleblower Program". Report SEC Fraud. Retrieved 2018-01-09.
  47. ↑ "Foreign Tipster Gets More Than $30M, SEC's Largest Whistle-Blower Award". www.bna.com. Retrieved 2018-01-09.
  48. ↑ "Awards Granted - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  49. ↑ "SEC Strikes Fear With First Award To Compliance Pro - Law360". www.law360.com. Retrieved 2018-01-09.
  50. ↑ "Awards Granted - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  51. ↑ "Awards Granted - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  52. ↑ "SEC Can Turn Most-Trusted Execs Into Whistleblowers - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  53. ↑ "SEC.gov | Former Company Officer Earns Half-Million Dollar Whistleblower Award for Reporting Fraud Case to SEC". www.sec.gov. Retrieved 2018-01-09.
  54. ↑ "Hedge fund settles SEC case over whistleblower retaliation". Reuters. 16 June 2014. Retrieved 2018-01-09.
  55. ↑ "Awards Granted - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  56. ↑ "SEC Gives More Than $600,000 to Whistleblower in Retaliation Case - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  57. ↑ "SEC Accuses Firm of Whistleblower Retaliation - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  58. ↑ Elstein, Aaron. "SEC fines firm for punishing a whistle-blower". Crain's New York Business. Retrieved 2018-01-09.
  59. ↑ "SEC.gov | SEC Announces Enforcement Results for FY 2016". www.sec.gov. Retrieved 2018-01-09.
  60. ↑ "SEC.gov | SEC Announces $7 Million Whistleblower Award". www.sec.gov. Retrieved 2018-01-09.
  61. ↑ "Not an inside job: How two analysts became SEC whistleblowers". Reuters. 25 April 2017. Retrieved 2018-01-09.
  62. ↑ Popper, Nathaniel (2015-12-18). "JPMorgan to Pay $307 Million for Steering Clients to Own Funds". The New York Times. ISSN 0362-4331. Retrieved 2018-01-09.
  63. ↑ "Labaton Chases Whistleblower Record In JPMorgan Case - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  64. ↑ "J.P. Morgan Will Pay $307 Million to SEC, CFTC for Failing to Disclose Conflicts - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  65. ↑ "Bank of America to Pay $415 Million to Settle SEC Probe - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  66. ↑ "Bank of America Pays $430M in Settlement for Misusing Customers' Cash - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  67. ↑ "BofA to Pay $415 Million Over Claims It Misused Client Funds - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  68. ↑ "Corporate Disclosures & Financials - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  69. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  70. ↑ "Offering Fraud - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  71. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  72. ↑ "Market Manipulation - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  73. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  74. ↑ "Insider Trading - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  75. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  76. ↑ "Trading & Pricing - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  77. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  78. ↑ "Foreign Corrupt Practices Act - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  79. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  80. ↑ "Market Events - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  81. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  82. ↑ "Unregistered Offerings - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  83. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  84. ↑ "Municipal Securities & Public Pensions - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  85. ↑ "Knowledge is Power—The Securities Law Handbook" (PDF). Labaton Sucharow. May 2017.
  86. ↑ "Point-Counterpoint: Dodd-Frank Whistleblower Rules - Law360". www.law360.com. Retrieved 2018-01-09.
  87. ↑ "Implementation of the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934" (PDF).
  88. ↑ "SEC Adopts Rules to Establish Whistleblower Program". www.sec.gov. Retrieved 2018-01-09.
  89. ↑ "U.S. high court to review scope of Dodd-Frank whistleblower protection". Reuters. 26 June 2017. Retrieved 2018-01-09.
  90. ↑ "Interpretation of the SEC's Whistleblower Rules Under Section 21F of the Securities Exchange Act of 1934 - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  91. ↑ "U.S. high court to review scope of Dodd-Frank whistleblower protection". Reuters. 26 June 2017. Retrieved 2018-01-09.
  92. ↑ "National Exam Program Risk Alert" (PDF). 24 October 2017.
  93. ↑ Devine, Jordan Thomas and Tom. "Wall Street's New Enforcers Aim to Muzzle Whistle-Blowers". DealBook. Retrieved 2018-01-09.
  94. ↑ Thomas, Jordan (18 July 2014). "Request for rulemaking petition and the issuance of a Policy Statement Regarding Certain Aspects of the Dodd-Frank Whistleblower Program" (PDF).
  95. ↑ "SEC Urged to Restrict Employee Nondisclosure Agreements - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  96. ↑ "National Exam Program Risk Alert" (PDF). 24 October 2014.
  97. ↑ "De Facto Gag Clauses: The Legality of Employment Agreements That Undermine Dodd-Frank's Whistleblower Provisions - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  98. ↑ "SEC.gov | The SEC as the Whistleblower's Advocate". www.sec.gov. Retrieved 2018-01-09.
  99. ↑ "2016 Annual Report to Congress on the Dodd-Frank Whistleblower Program" (PDF).
  100. ↑ "SEC-Form TCR - Report SEC Fraud". Report SEC Fraud. Retrieved 2018-01-09.
  101. ↑ "Regulation 21F, Rule 9(a)" (PDF).


This article "SEC Whistleblower Program" is from Wikipedia. The list of its authors can be seen in its historical and/or the page Edithistory:SEC Whistleblower Program. Articles copied from Draft Namespace on Wikipedia could be seen on the Draft Namespace of Wikipedia and not main one.


Retrieved from "https://en.everybodywiki.com/index.php?title=SEC_Whistleblower_Program&oldid=955050"
License CC BY-SA 3.0
Powered by MediaWiki
Powered by Semantic MediaWiki