Subject: Comment letter to proposed rules change for Whistleblowers
From: Christopher Diiorio

July 2, 2018

https://www.sec.gov/news/press-release/2018-120

 

I am sending this e mail per SEC instructions as comments on the SEC proposed changes to the "Interpretive Guidance" for whistleblowers.
The SEC is proposing the following interpretive guidance:

"Under the proposed guidance, in order to qualify as "independent analysis", a Whistleblower's submission must provide evaluation, assessment, or insight beyond what would REASONABLY APPARRENT to the Commission from publicly available information."

WOW. 

Let's focus on the chosen words "REASONABLY APPARENT"
For example, the Madoff Ponzi scheme. Ponzi's are infinitely simple to detect, There are no counter parties for trades. So, Ponzi's SHOULD qualify as "REASONABLY APPARENT".
Yet, it took the SEC a DECADE to finally investigate. 
Gross incompetence and or corruption at the SEC is not a new phenomenon.
What SHOULD be "REASONABLY APPARENT" and what ARE "REASONABLY APPARRENT" to the grossly corrupt, criminal organization known as the SEC can leave a lot to interpretation.
How many SEC attorneys did it take to come up with the term "REASONABLY APPARENT"?
The same attorneys investigating WorldCom? Enron? HealthSouth? GE? Theranos? Knight/KCG/Virtu? Deutsche Bank Mirror trades? Oh, I forgot, there was NO SEC investigation for that, etc etc etc.
The SEC failures to detect and stop "REASONABLY APPARENT" Securities Law violations are too numerous to count. The Latest: "Bitcoin is not a security." when there is settled case law that if applied would CLEARLY PROVE it is in fact a security: SEC V SG Ltd.
SEC V SG Ltd would also show Bitcoin (Like Micro cap securities Jay) is a money laundering vehicle of choice for criminals.
The SEC failure to detect and stop "REASONABLY APPARENT" securities law violations is well documented. Which begs the question: WHY is the SEC changing the definition of "independent analysis"?
The grossly corrupt SEC proposed "Interpretive guidance" with regards to the "independent analysis" for Whistleblowers is an admission of guilt rather than an attempt to collect  "More pertinent information".
What the SEC is admitting with the term "REASONABLY APPARENT":
"We know there are violations of Securities Laws. We just haven't done anything about it"
Because IF a whistleblower submits a tip where the Commission is already aware of the "REASONABLY APPARENT" violation, then, WHY hasn't the SEC already brought a complaint??????
Quite the admission.
There are "REASONABLY APPARENT Securities Law violations the SEC is aware of but done ABSOLUTELY NOTHING to stop. 
IF the "interpretive guidance" changes to Whistleblower information is changed as proposed, then the question for the investing public is:
WHY isn't the SEC prosecuting "REASONABLY APPARENT" Securities law violations?
Regards,
Christopher Diiorio
Whistleblower