December 15, 2010
The SEC should stick with its proposed rules on compliance programs and ignore the self-serving proposals by the fraud lobby to require internal reporting.
As the SEC moves forward with its new program, it should ignore the strident howls of corporate lawyers beseeching the agency not to shred the fabric of corporate governance, and should rely on experience rather than rhetoric. The power and money of corporate lobbyists should not trump the proven track record of success established by whistleblowers under the False Claims Act.