Monthly Archives: May 2013

Dodd Frank – Procedural Aspects Of The Whistleblower Bounty (Part I)

Procedures For Submitting Information To The SEC Have Been Simplified The Final Rules make it significantly easier for individuals to submit information to the SEC concerning allegations of alleged violations of federal securities laws. A person who wishes to file … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part VIII)

An Employee May Be A Whistleblower for Purposes Of Dodd-Frank’s Anti-Retaliation Provisions, Even If He Or She Is Not A Whistleblower For Purposes Of Dodd-Frank’s Bounty Provisions Under the “bounty” provision, a whistleblower who provides “original information” to the SEC … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part VII)

Criminal Violators Can Be Whistleblowers Under Dodd-Frank Rejecting the suggestion by some commenters that the rules exclude from “whistleblower” status those who are themselves guilty of violations, the SEC notes that “[i]nsiders regularly provide law enforcement authorities with early and … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part VI)

Exceptions To The Exclusions From The Definition Of A Whistleblower Under Dodd-Frank The categories of individuals listed above may nevertheless be eligible for whistleblower status under certain circumstances. For attorneys, the Final Rules include an exception for attorney disclosures permitted … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part V)

Individuals In Compliance-Related Roles Are Excluded From The Definition Of A Whistleblower Under Dodd-Frank Dodd-Frank defines original information as information that is: • “Derived from the independent knowledge or analysis of a whistleblower”; • “Not known to the SEC other … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part IV)

Individuals Who Have A Legal Or Contractual Duty To Report Violations Are Excluded From The Definition Of A Whistleblower Under Dodd-Frank To qualify for receipt of an award under Dodd-Frank, a whistleblower must have “voluntarily” provided “original information” to the … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part III)

Although Dodd-Frank Explicitly Defines A “Whistleblower” In A Way That Only Includes Those Who Provide Information To The SEC, An Exception Has Been Carved Out That Is Rooted In A “Catch-All” Part Of The Law Another Part Of Dodd-Frank’s “Catch-All” … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part II)

Although Dodd-Frank Explicitly Defines A “Whistleblower” In A Way That Only Includes Those Who Provide Information To The SEC, An Exception Has Been Carved Out That Is Rooted In A “Catch-All” Part Of The Law Dodd-Frank’s “Catch-All” Provision Providing Whistleblower … Continue reading

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Dodd Frank – Who Can Qualify As A Whistleblower (Part I)

The Basic Definition Of A Whistleblower Under Dodd-Frank The Dodd–Frank Act defines a whistleblower making disclosures under the SEC’s jurisdiction as follows: “The term ‘whistleblower’ means any individual who provides, or 2 or more individuals acting jointly who provide, information … Continue reading

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Dodd Frank – Introduction

In an earlier posts here and here, we briefly discussed Dodd Frank. This week, we intend to get into the weeds a little bit with Dodd Frank. Our paper discusses Dodd Frank in great detail. The whistleblower and bounty hunter … Continue reading

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