September 17, 2018
Monday, September 17, 2018
Subject: Please Withdraw the Proposed Rule Amendments to the SEC Whistleblower Program -- File Number S7-16-18
Dear Securities and Exchange Commission,
I write to strongly oppose the proposed amendments to the rules governing the SEC whistleblower program (File Number S7-16-18). The proposed rule amendments will weaken and undermine the deterrent effect of rewarding whistleblowers.
I call your attention to the public statements issued by Commissioners Stein and Jackson and the Law360 Op-ed "The Problem With SEC's Plan To Cap Whistleblower Awards." (https://bit.ly/2L0WTaJ) These statements outline my reasoning as to why the proposed amendments will undermine the policing of Wall Street.
Specifically, the proposed amendment to the rules capping rewards in the largest cases to the lowest percentage rate should be withdrawn. Furthermore, the SEC should ensure that every employee, regardless of position or title, can disclose corporate fraud directly to the SEC. Any requirement that compliance officers, managers or directors work internally with the company before reporting to the SEC must be struck from the rules.
I request that you meet personally with whistleblower experts from the National Whistleblower Center to obtain additional information as to why the proposed amendments to the rules governing the SEC whistleblower program should not be implemented.
Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources.
Sincerely,
Christopher Lish
San Rafael, CA