Sep. 18, 2018
Dear Sirs, I refer to your proposed rule changes. I have direct experience of the Whistleblower Program as I submitted a number of TCR's in the past. There are a number of flaws in the program but from experience I believe these were deliberate with the purpose to deceive the public and deceive ordinary shareholders. I can't be very specific as I am aware that comments will be published. I am an Accountant and I am aware that a former Employer was allowed to engage in significant Accounting Fraud. A number of employees were also working for the Intelligence Agencies and these employees were involved with a number of the programs disclosed by Edward Snowden. The Whistleblower program includes wording to prevent retaliation from an Employer but it doesn't cover retaliation by a third party eg retaliation by the Intelligence Agencies. The Office of the Whistleblower have stated that they close cases in the "public interest" without making information public. This practice should cease as ordinary shareholders and employees are not being made aware of significant Accounting Fraud and are therefore not in a position to take class actions. The Office of the Whistleblower frequently used the term "Enhanced Communication" in their conversations with me. The definition of this term and why they use it should be included in the rule changes. The office of the Whistleblower should explain why they close cases without a proper investigation. They stated to me it was for various reasons including the fact that Accounting Fraud is not listed as a priority for the SEC; because of lack of resources etc. Sufficient , impartial and independent resources need to be given to the program. The SEC only grant awards after a "successful enforcement". Awards should be granted where cases are closed without enforcement because of the perceived "public interest". The SEC should allow for TCR submissions by e-mail. The SEC are allowing whistleblowers such as myself to sign Confidential Non Disclosure Agreements with former employers. I tried to share all my direct knowledge of Accounting Fraud with the SEC but the SEC were not interested in meeting with me and allowed me to destroy evidence of Accounting Fraud. The program should address the issue of confidentially agreements and take action against Employers & Third Parties that coerce employees and former employees into signing these type of agreements. The implications of the US Patriot Act and other rulings by the FISA courts should be disclosed in the proposed rule changes, If you need any additional information or clarification you can get back to me. I would be grateful if you can confirm receipt of this e-mail. Regards Liam