Jul. 30, 2018
Dear Securities and Exchange Commission,
I very strongly oppose the proposed amendments to the rules governing the SEC whistleblower program (File Number S7-16-18). The proposed rule amendments will drastically weaken and undermine the deterrent effect of rewarding whistleblowers.
If you have not already done so, please read the public statements issued by Commissioners Stein and Jackson and the Law360 Op-ed “The Problem With SEC's Plan To Cap Whistleblower Awards.” (https://bit.ly/2L0WTaJ) These statements outline my reasoning as to why the proposed amendments will undermine the policing of Wall Street.
Specifically, the proposed amendment to the rules capping rewards in the largest cases to the lowest percentage rate should be withdrawn. Furthermore, the SEC should ensure that every employee, regardless of position or title, can disclose corporate fraud directly to the SEC. Any requirement that compliance officers, managers or directors work internally with the company before reporting to the SEC must be struck from the rules. Finally, rules must be implemented that require the timely payment of rewards to qualified whistleblowers.
Finally, please meet personally with whistleblower experts from the National Whistleblower Center to obtain additional information as to why the proposed amendments to the rules governing the SEC whistleblower program should not be implemented.
Sincerely,
Mr. David Addison