Oct. 19, 2019
Dear Rule Comments, Please request that the U.S. Securities and Exchange Commission (SEC) withdraw proposed revisions of Exchange Act Rule 21F-6. The proposed revisions would reduce incentives now in the very helpful and successful whistleblower program. Whistleblowers are a very beneficial part of SEC regulation of free and fair markets. Whistleblowers have helped the SEC recover over $1.7 billion from market fraud, manipulation, and theft over the past decade, including more than $901 million in disgorgement of stolen gains and interest. Despite success of the SEC whistleblower program, the Commission has recently proposed two amendments to its program that would be very detrimental to whistleblowers and undermine the success of the program. Proposed revisions to Exchange Act Rule 21F-9(e) would create an unrealistic reporting procedure that would disqualify a vast number of whistleblowers simply because they either elected to attempt to resolve matters within their companies or discussed the matter with anyone else, rather than going directly through the SEC’s specific reporting procedures. Proposed revisions to Exchange Act Rule 21F-6 would also disincentivize whistleblowers from coming forward by placing an arbitrary limit on whistleblower rewards, especially in cases where the whistleblower uncovered massive frauds. Congress has rejected such arbitrary limits, but the Commission’s proposed rule would authorize these drastic reductions in the amount of rewards in major fraud cases. Rewards must be based on the level of the whistleblower’s contribution to the successful outcome of the case. They are essential in encouraging whistleblowers to step forward with high-quality information on the largest cases. Accountability is extremely important to free and fair markets and the rule of law. Please oppose the proposed changes by the SEC and maintain its current robust whistleblower program. Sincerely, Sincerely, Edward Main [redacted]