Ropes & Gray banking practice co-leader Mark Nuccio posted a new article to his Dodd-Frank Watch blog on Boardmember.com. The post covers the May 25 SEC vote to adopt a rule creating a whistleblower program that was mandated by the Dodd-Frank Act.
Nuccio writes, “The whistleblower program is primarily intended to reward individuals who expose violations and who provide significant evidence that helps the SEC bring successful cases. Leaving aside fears of actual whistleblower claims, the existence of such a program will, in and of itself, justify dialing up focus on securities-related compliance efforts.”
The post addresses the new program’s relationship to existing internal corporate compliance programs; the definition of a “whistleblower”; anti-retaliation provisions designed to protect whistleblowers; and additional internal considerations for companies raised by the rule.
Nuccio writes, “The whistleblower program is primarily intended to reward individuals who expose violations and who provide significant evidence that helps the SEC bring successful cases. Leaving aside fears of actual whistleblower claims, the existence of such a program will, in and of itself, justify dialing up focus on securities-related compliance efforts.”
The post addresses the new program’s relationship to existing internal corporate compliance programs; the definition of a “whistleblower”; anti-retaliation provisions designed to protect whistleblowers; and additional internal considerations for companies raised by the rule.
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