Sep. 17, 2018
Dear Securities and Exchange Commission, I write in regard to the proposed amendments to the rules governing the SEC whistleblower program (File Number S7-16-18). When any department wants to change rules, I believe it is a right of the public to not only know what is being changed, but how the changes will effect the actions of that department or its end results. I fully support whistleblowers and want their input made public at all times. I am tired of games being played between departments with oversight requirements and the companies/institutions they are supposed to oversee, working together to keep things 'quiet'. That is NOT the role of the SEC and it should not be party to any type of changes that will achieve this silence, under the rug, wink, wink behavior. The SEC proposed these changes with no input from the whistleblower community, yet adopted a position consistent with the long-standing and flimsy viewpoint advanced by the anti-whistleblower U. S. Chamber of Commerce (“Chamber”). The chamber is not a friend of consumers. It is my understanding that the National Whistleblower Center filed a Freedom of Information Act (FOIA) request seeking documents related to lobbying efforts by Wall Street firms and the Chamber of Commerce that gave rise to the SEC’s proposed rules. The SEC determined that the NWC had a “compelling need” to receive these documents “on an expedited basis” and determined that there were 15,877 emails that could be responsive to NWC’s request. These included 1,078 emails that referenced both “whistleblower” and “Chamber of Commerce” created between January 2, 2017 and June 29, 2018. Despite its agreement to expedite the release of these documents, the SEC will not release them until after the comment period. The delay makes me question the commitment the SEC should have regarding transparency and respect for the public's interest. Therefore, I urge the SEC, in the interest of transparency, and the public's right to know, extend the public comment period for its proposed rules on the Whistleblower Program until 60 days after the documents requested by the NWC’s FOIA request have been released. If the comment period is not extended, I agree with the concerns raised in the NWC’s letter filed with the Commission on September 17, 2018, linked here: https://bit.ly/2xqGUts. Sincerely, Ms. stacy rauch 30 Park Ave New York, NY 10016 212-555-1122