Sep. 03, 2020
Dear Rule Comments, In order to protect the success of the whistle blower program, you must reconsider proposed amendments. Whistleblowers have proven essential to effective control of wrongdoers ever present where large sums of money are at risk. Proposed revisions to Exchange Act Rule 21F-9(e) would create unrealistic reporting procedures that would disqualify a vast number of whistleblowers, simply because they reported their concerns to the wrong office at the SEC. Proposed revisions to Exchange Act Rule 21F-6 would also disincentivize whistleblowers from coming forward by placing an arbitrary limit on whistleblower rewards in spite of rejection of these arbitrary limits. Rewards must be based on the level of the whistleblower’s contribution to the successful outcome of the case. Proposed revisions to Exchange Act Rule 21F-2(d) would additionally take away the SEC’s authority to sanction and regulate companies that retaliate against internal whistleblowers. Due to the vast majority of corporate whistleblowers utilizing internal reporting channels, this revision would have major national and international impact. I urge you to reconsider these proposed amendments to ensure your robust whistleblower program continues. If you have any questions about the potential impacts of these amendments or would like more information, please contact the National Whistleblower Center at info@whistleblowers.org Sincerely, Sincerely, Marian Severt