Subject: File Number S7-16-18
From: Terry Davis
Affiliation:

Feb. 24, 2019

This is a comment on the SEC's proposed changes to the whistleblower rules. 



Within the last thirty days, a 70% federal income tax has become a popular source of discussion in Washington D.C.  With a legal fee of one-third a whistleblower award, many whistleblowers will receive a mortifyingly small recovery for placing their careers at risk.  In states with large financial centers (for example New York, Chicago) high state and local taxes could leave the whistleblower owing money to some external party.  



As you know, payment of whistleblower awards can take many years.  A higher tax rate, at the time an award is paid, is a possibility.  Taxes and legal fees are not easily evaded.  A sympathetic ear is unlikely to be found, even if a whistleblower award causes bankruptcy.  Accordingly, the SEC need not continue on it's course to disadvantage the public whistleblower, that work is usually being accomplished elsewhere. 



Finally, the temptation to disadvantage the public whistleblower may prove too strong for some government employees.  Whistleblowers are a diverse group.  They add no political influence, even if an award is successfully paid.  So, because whistleblower lawyers and advocates seem to gather here, I would like to suggest the cautious, respectful naming of government employees who will influence the new whistleblower rules.  Those names can then be discussed, for their influence on whistleblower policy, both good and bad.  Reddit.com has an anonymous discussion area called "Wall Street".  All respectful comments are welcome there.  Other internet sites are also available.  A person unjustly impeding whistleblowers might have their activities displayed as their top internet search result.  This may help alleviate the pressure to disadvantage whistleblowers, who are usually individuals without political competence.  



Please report, or discuss on the internet, any personnel who attempts to go unnoticed, while unjustly causing a disadvantage to whistleblowers. 



Thank you, 

Terry Davis