August 24, 2018
If enacted, the Proposed Rules will significantly weaken the SEC's ability to protect investors and cause the SEC to be inefficient in its investigations.
I wish to reiterate the comments by others that the Proposed Rules are:
1.) Based on non-existent or insufficient data
2.) Do not properly take into account the calculous of would be Whistleblowers
3.) Will result in less Whistleblower tips and longer delays in processing claims
4.) Does not address any of the fundamental efficiency or structure problems of the Whistleblower program
5.) Etc.
Furthermore, I wish to specifically point out the fact that the SEC's Whistleblower program does not provide the appropriate avenues of due process as provided for by the Administrative Procedure Act (APA).
For example, although statute and case law requires any Administrative Adjudication Office to accept requests for expedited processing, the SEC's Whistleblower Office has categorically denied or ignored requests for expedited processing - even when this unjustly prejudices the Whistleblower and causes unfair risk to life, loss of properly, and other damages.