Regulatory: Reviewing the Dodd-Frank Whistleblower Program’s 2011 annual report

Companies should use the SEC’s findings to review their internal reporting and compliance programs.

Section 924(d) of the Dodd-Frank Act requires the Securities and Exchange Commission’s (SEC) Office of the Whistleblower to report annually to Congress on whistleblower complaints and its responses. In November 2011, the SEC issued its inaugural annual report on the Dodd-Frank Whistleblower Program. Because the final rules implementing the Dodd-Frank Act did not become effective until Aug. 12, 2011 and the SEC’s fiscal year ended Sept. 30, 2011, the report includes only seven weeks of data describing just 334 whistleblower submissions. Despite the small sample, the report offers a significant takeaway for corporations: internal reporting and compliance programs matter.

Submissions summary

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Lisa Noller

Lisa M. Noller is a partner and member of the Government Enforcement, Compliance & White Collar Defense; Business Litigation & Dispute Resolution and Securities Enforcement...

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