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Dodd-Frank Whistleblower Rules

The Dodd-Frank Act was designed by Congress to hold Wall Street accountable and prevent another financial meltdown. A centerpiece of that reform was strong whistleblower protections. Corporations tried to kill the law through the back door by lobbying the Securities and Exchange Commission to pass rules that would limit the protections for whistleblowers and the effectiveness of the law.

The rules at issue affect every American from the price you pay at the gas pump (commodities) to the integrity of your retirement accounts (securities). On May 25, 2011, the SEC voted 3-2 to approve final rules that adopted many of the NWC's proposals, including incentives for employees who report wrongdoing internally and reward employees whether they choose to file their whistleblower claims with the company or with the government.

View Sections Pertaining to Whistleblowers Here

 


Other Resources

 

NWC Report to the SEC: "Impact of Qui Tam Laws on Internal Compliance" - This study examines False Claims Act cases from 2007 to present and finds that there is "no negative impact" on internal corporate compliance programs. 

To learn more about your rights as a whistleblower please read The Whistleblower's Handbook: A Step-by-Step Guide to Doing What's Right and Protecting Yourself or attend one of our upcoming seminars on the Dodd-Frank whistleblower rules. 

Securities Exchange Commission Whistleblower Rule Links


SEC Final Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934
Approved May 25, 2011 by a vote of 3-2

SEC Proposed Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934 

SEC webpage listing all the public comments submitted

NWC Meetings with SEC

January 25, 2011 Meeting with Division of Enforcement

February 10, 2011 Meeting with Commissioner Aguilar

February 11, 2011 Meeting with Commissioner Paredes

February 15, 2011 Meeting with Commissioner Walter

March 11, 2011 Meeting with Commissioner Casey

March 28, 2011 Meeting with Chairman Schapiro

NWC Public Comments

November 1, 2010 - Letter to SEC opposing corporate lobby position, including comments from Baker Donelson and Arent Fox

November 22, 2010 - Letter to Chairman Schapiro explaining that Proposed Rules violate Congressional intent

December 17, 2010 - Formal rulemaking letter with report entitled "Impact of Qui Tam Rules on Internal Compliance"

December 18, 2010 - Updated "Impact of Qui Tam Rules on Internal Compliance" with corrected links

January 25, 2011 - Materials for NWC's meeting with SEC Division of Enforcement: Letter to Chairman Schapiro appling Chevron to Proposed Rules, marked-up version of Proposed Rules, updated NWC reported "Impact of Qui Tam Rules on Internal Compliance", 10 C.F.R. 50.7 marked-up, Federal Acquisition Regulations, and 48 C.F.R. 52.203-13 marked-up

February 10, 2011 - Letter to Commissioners explaining the proposed rules' impact on the ability of US to enforce the Foreign Corrupt Practices Act

March 7, 2011 - Letter to Chairman Schapiro responding to Chamber of Commerce's incorrect attacks of the NWC's December 17, 2010 report

March 17, 2011 - Letter to SEC with provision-by-provision analysis of proposed rules with suggested revisions and justifications for revisions

May 16, 2011 - Letter to Chairman Schapiro and Gensler regarding the impact of the first reported decision under the Dodd-Frank Act on the rulemaking process

Letters in Support of NWC position

Senator Charles Grassley (R-IA) - May 10, 2011 letter expressing "serious concerns" with the Proposed Rules

National Coordinating Committee for Multiemployer Plans (NCCMP) - December 17, 2011 formal rulemaking comment supporting strong whistleblower rules to protect investors

NCCMP - April 25, 2011 supplemental comment summarizing rampant fraud on Wall Street and why it presents strong case for whistleblower protections

Comments by Commissioners introducing Final Rules

Comments by Chairman Mary L. Schapiro

Comments by Commissioner Elisse B. Walter

Comments by Commissioner Troy A. Paredes

Comments by Commissioner Luis A. Aguilar

Comments by Commissioners introducing Proposed Rules


Comments by Chairman Mary L. Schapiro

Comments by Commissioner Elisse B. Walter

Comments by Commissioner Troy A. Paredes

Comments by Commissioner Luis A. Aguilar

Comments by Corporate Lobby

Baker Donelson letter - Representing corporate lobby position

Arent Fox Letter - Representing corporate lobby position

Chamber of Commerce Letter - Attacking the NWC's report "Impact of Qui Tam Rules on Internal Compliance"

 

Commodity Futures Commission Whistleblower Rule Links


CFTC Proposed Rules for Implementing the Whistleblower Provisions of Section 23 of the Commodity Futures Act

Transcript of CFTC open meeting on Proposed Whistleblower Rules

CFTC webpage listing all the public comments submitted

NWC Public Comments

November 4, 2010 - Letter to CFTC opposing corporate lobby position, including comments from Baker Donelson and Arent Fox

February 4, 2011 - Formal Rulemaking Comment "Impact of the Dodd-Frank Qui Tam Laws on Internal Compliance"

February 11, 2011 - Updated Formal Rulemaking Comment "Impact of the Dodd-Frank Qui Tam Laws on Internal Compliance"

March 9, 2011 - Letter to CFTC responding to Chamber of Commerce's incorrect attacks of the NWC's December 17, 2010 report to the SEC

March 17, 2011 - Letter to CFTC with provision-by-provision analysis of SEC proposed rules with suggested revisions and justifications for revisions that are applicable to CFTC's proposed rules

May 16, 2011 - Letter to Chairman Schapiro and Gensler regarding the impact of the first reported decision under the Dodd-Frank Act on the rulemaking process 

June 6, 2011  - Letter to CFTC suggesting that they harmonize the CFTC's Final Rules with the SEC's Final Rules