SEC Issues Final Rules for Whistleblower Bounties

This past Wednesday, May 25, 2011, the SEC issued its final rules for the Whistleblower Incentives and Protection provisions of the Dodd-Frank Act.

Key points:

  • Whistleblowers do NOT have to report violations internally before going to the SEC;
  • Attorneys, auditors and internal compliance personnel are generally not eligible to be whistleblowers;
  • Culpable whistleblowers are not necessarily ineligible, but any reward may be reduced;
  • Multiple proceedings based on the same nucleus of fact can be aggregated to meet the $1 million threshold to get a whistleblower bounty;
  • Information provided must be specific, credible and timely.

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