What, If Anything, Impedes The SEC’s Whistleblower Rule?
As I suspected, law firms are churning out memoranda on the SEC’s recent enforcement actions involving alleged impediments to whistleblowers. While accurately, summarizing these actions, I’m not sure...
View ArticleWhy You May Want To Reconsider Promising Confidentiality To Whistleblowers
In this recent post, I suggested that absolute guarantees of confidentiality to whistleblowers may be counterproductive. In today’s post, I will elaborate on why. The scope of the promise may be...
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Is This The SEC Or The Lotto?
Last week, the Securities and Exchange Commission trumpeted that whistleblower awards have now exceeded $100 million, or a million Benjamins! “Chance, the loss or gain of a moment” The SEC’s total...
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Five Propositions Concerning The SEC Whistleblower Program
Congress, not the Securities and Exchange Commission, established the whistleblower program six years ago as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act. As the program has...
View ArticleA New Regulatory Paradigm For The SEC?
Many are speculating on the future of federal securities regulation as a result of the election of Donald J. Trump and the concomitant Republican control of both houses of Congress. Broc Romanek, for...
View ArticleSEC Hands Out Millions While Leaving The Public In The Dark
Last week, the Securities and Exchange Commission issued a press release announcing its decision to award $20 million “to a whistleblower who promptly came forward with valuable information that...
View ArticleIs This SEC Claim False And Misleading?
Last week, the Securities and Exchange Commission announced yet another whistleblower award. According to the SEC, the award totals more than $5.5 million dollars. Tellingly, we don’t, and won’t,...
View ArticleSEC Continues To Pay Out Millions In Secrecy
Earlier this week, the Securities and Exchange Commission announced awards to three whistleblowers totaling more than $7 million. That is about all anyone can say about the awards. The SEC’s order is...
View ArticleDoes Whistleblower Protection Extend To Disclosures To Your Mom Or The Press?
California and federal law establish ample protections for whistleblowers. These protections can be found in numerous laws, including the Sarbanes-Oxley Act, the Dodd-Frank Act, and Section 1102.5 of...
View ArticleExactly What Part Of “To The Commission” Is Ambiguous?
The Dodd-Frank Act gave us many things, including Section 21F of the Securities Exchange Act of 1934. Section 21F, prohibits employers from retaliating against a “whistleblower”. 15 U.S.C. §...
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