Subject: File No. S7-16-18
From: Taylor S Amarel

September 12, 2018

The SEC's Whistleblower Program is underfunded, understaffed, and most importantly undervalued.

Much of the discussing for these proposed rules is aimed at addressing a backlog in whistleblower claims. However, throughout the Commissions discussion and proposal of these rules - not a single reason was given as to why this backlog could not be addressed by increasing funding and the number of staff in the SEC's Whistleblower Office.

Currently, the number of staff presently assigned to the OWB is only 21 and the total annual expenditure for FY17 was $2,753,111.

For a program that has led to hundreds of millions of dollars in fines and sanctions, it is definitely worth considering increasing the number of staff to address the backlog. As they are written, the proposed rules are not guaranteed to have any impact on the backlog but will most definitely provide additional concerns and ambiguity to would-be-whistleblowers and perhaps discourage them from reporting wrongdoing.

(Attached File #1: s71618-4334228-173237.pdf) (Attached File #2: s71618-4334229-173237.pdf)