Subject: File No. S7-16-18
From: Anonymous Anonymous

September 9, 2018

Based on Annual Reports, OIG Report, and internal documents the Whistleblower office conducts a number of operations as listed below. However, because no data has been released it is impossible to determine how much time and resources the SEC dedicates to each area, therefore while the proposed rule changes may address one or two areas, they do not address other areas which when combined may take up the bulk of the OWBs time:

1.) Managing intake of tips
2.) Managing intake of Whistleblower claims
3.) Collecting documents needed for Whistleblower adjudication
4.) Drafting and deciding on Whistleblower claim
5.) Presenting claim to commission.

Furthermore, in my personal experience that OWB spends significant time and resources dealing with the following matters:

1.) Answering queries from the public (could be solved with a better FAQ)
2.) Corresponding with and communicating with Whistleblowers (often scheduling multiple calls to repeat the same information to multiple Whistleblowers - could be solved with a better FAQ.)
3.) Adding supplemental information to previous tips
4.) Accepting documents via physical mail
5.) Forwarding documents to enforcement staff
6.) Recovering spoiled whistleblower information
7.) Etc.

Although the SEC is of the position that the proposed rules will decrease the processing time for Whistleblower claims it only addresses a very small portion of the OWB duties and is therefore will only have a limited impact (if any) on the processing times.