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Day: December 1, 2017

The Friday List: 10 Important Facts about the SEC Whistleblower Program

Today, we offer our “Friday List,” an occasional feature summarizing a topic significant to investment management professionals interested in regulatory issues.  Our Friday Lists are an expanded “Our Take” on a particular subject, offering our unique (and sometimes controversial) perspective on an industry topic.

The SEC recently announced that it has now ordered more than $1 Billion in financial penalties based on tips from whistleblowers.  Also, the Supreme Court is currently deciding the definition of a “whistleblower.”  We felt it a good time to offer 10 significant facts about the SEC’s Whistleblower program, which was created in 2012 as part of the Dodd Frank-Act.


10 Important Facts about the SEC Whistleblower Program


  1. The SEC has awarded more than $175 Million to 49 whistleblowers.
  2. The largest whistleblower award to date is $30 Million.
  3. A whistleblower is entitled to 10%-30% of monetary sanctions if the sanctions imposed exceed $1 Million.
  4. Both an outsider and a former employee can be a whistleblower.
  5. Covered firms may not take retaliatory job action against a whistleblower.
  6. Employee separation and non-compete agreements may not limit an employee’s whistleblower rights.
  7. Directors can be liable for whistleblower retaliation.
  8. Unless the Supreme Court decides otherwise, internal reporting, is sufficient, but not required, to become a protected whistleblower.
  9. In-house counsel and compliance officers are entitled to whistleblower protections.
  10. Firms must adopt whistleblower procedures.