SEC's Suggestion Box Is Out for Whistleblower Rules

Law 360 published an AGG Client Alert written by Partners Joseph Alley Jr., Aaron M. Danzig and Robert F. Dow titled “SEC’s Suggestion Box Is Out for Whistleblower Rules” (subscription may be required to view). On November 3, 2010, the Securities and Exchange Commission (SEC) released proposed rules for the whistleblower program established by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The whistleblower program requires the SEC to pay an award or bounty to eligible whistleblowers who voluntarily provide the SEC with original information about a violation of securities laws, which then leads to a successful enforcement action. This will likely lead to more referrals to the SEC and may result in employees circumventing their companies’ compliance programs and running directly to the government to obtain a potential whistleblower bounty. The Client Alert details the proposed rules and how they could affect you and your company.