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The SEC Adopts Game-Changing Rules for Whistleblowers and their Employers by Douglas W. Baruch
Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office
Dixie L. Johnson
Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office
William F. Johnson
Fried, Frank, Harris, Shriver & Jacobson LLP - New York Office
Carmen J. Lawrence
Fried, Frank, Harris, Shriver & Jacobson LLP - New York Office
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May 31, 2011
Previously published on May 25, 2011
Today, with two Commissioners dissenting, the SEC adopted final rules implementing the new whistleblower program created last July by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). The rules are a game-changer for corporate compliance programs and for the officers and directors who oversee whistleblower procedures. The 305-page adopting release will be analyzed in the days, weeks and months ahead, but it is already apparent from statements made today by Chairman Mary Schapiro, Director of Enforcement Robert Khuzami, head of the SEC’s new Office of the Whistleblower, Sean McKessy and others that the SEC intends the new rules to:
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