August 21, 2018
Although I believe the SEC Whistleblower Program has many areas that need improvement - the Proposed Rules shy away from addressing the most critical areas.
For example, the Proposed Rules do nothing to help maintain the confidentiality of Whistleblowers. This is needed because on numerous occasions it has been proven that the mechanisms that the SEC and instructions given to Whistleblowers are inadequate and often conflict with the SEC's obligation to protect the identity of Whistleblowers.
Indeed, attached is a letter sent from the SEC that shows information sent via physical mail is at significant risk of theft - thus disclosing the Whistleblowers identity. I do not believe this is the only case of Whistleblower documents being intercepted or stolen.
More concerning is the fact that when queried, the SEC refused to provide any sort of "key" or encryption mechanism for documents sent via physical mail and further refused to use the secure Accellion upload system that the SEC already pays for.
This lack of concern for Whistleblower confidentiality shows a poor commitment to Whistleblowers and is just one of the many reasons Whistleblowers are losing trust in the Whistleblower program.
(Attached File #1: s71618-4239053-172915.pdf)