September 9, 2018
To whom this may concern,
Please see the quoted text below as a comment. This should be published under the name 'Anonymous'. Thank you.
"There is undoubtedly significant concern regarding the backlog of whistleblower claims and the multi-year (potentially decade-long) process which a whistleblower has to wait through before obtaining any concrete information or a potential award. I find this very detrimental to the purpose of the whistleblower program and these long delays significantly nullify the benefits of the whistleblower program as many whistleblowers would be unwilling to wait for an extended period of time, especially if the process is not transparent.
The proposed rule changes do not adequately address the delays nor do they provide for increased transparency. (In many ways the proposed rule changes cause whistleblowers more unwelcome and disincentivizing uncertainty.)
Throughout my experience with the SEC's Whistleblower Office, it is clear that the Whistleblower Office spends far too much time answering frequently asked questions, organizing supplemental information submissions, and responding to regular queries from whistleblowers.
1.) in more detail, the SEC's Whistleblower Office manually responds to hundreds of inquiries about how to submit information to the SEC that is larger than 50MB or how to submit information on a portable media device.
2.) Also, the SEC spends hundreds if not thousands of hours organizing supplemental information submissions into previous TCRs.
3.) Furthermore, the SEC manually responds to numerable whistleblowers that have asked for clarification on when they will receive an update, when a preliminary determination will be made, or if any more information is needed.
4.) Etc, (please see my previous suggestions to Ms. Norberg about improves to the information available at https://www.sec.gov/whistleblower that would significantly reduce the number of inquiries received from Whistleblowers and thus improve the efficiency of the Whistleblower office.)
Unfortunately, the proposed rules do nothing to address the above items that take up a considerable amount of staff time and resources. It is very disheartening that the proposed whistleblower rules have not been based off a study of staff hours and tasks and instead appear to be based off subjective opinions of cause and effect. In any case, to reach a tangible level of improvement and reduce the backlog of whistleblower claims the SEC should:
1.) Provide a more detailed FAQ section that touches on common questions about how to submit large files via flash drive or CD, what is the best format of a whistleblower tip, does the SEC want more information or less information, are exhibits required or is a narrative enough? Etc.
2.) The SEC should allow a whistleblower to upload supplemental information directly via the online Whistleblower Portal. Secure whistleblower submission systems, such as SecureDrop already allow a whistleblower to add supplemental information to their initial submissions. Doing so is not technically challenging and would allow the SEC to spend less time organizing supplemental information and significantly reduce the time for the supplemental information to reach enforcement staff.
3.) Most other federal agencies provide respondents and claimants with a timeline or monthly bulletin of processing times as well as what to expect during the waiting process. However, the SEC does not provide this information on its website, thus numerous whistleblowers inquire to the SEC on a regular basis requesting updates. The SEC then has to manually respond to these requests that could have been avoided should satisfactory information be available on the SEC's website."