Here’s some of what SEC chair Mary Jo White had to say last week in a speech at Northwestern University School of Law in Chicago, Illinois. Her talk was called “The SEC as the Whistleblower’s Advocate.”
Let me say a bit more about company compliance programs. When the [SEC] was considering its whistleblower rules, concerns were raised about undermining companies’ internal compliance programs. Some commenters urged that internal reporting be made a pre-condition to a whistleblower award. That was not done, but the final whistleblower rules established a framework to incentivize employees to report internally first.
A whistleblower’s participation in internal compliance systems is thus a factor that will generally increase an award, whereas interference with those systems will surely decrease an award. And, a whistleblower who internally reports, and at the same time or within 120 days reports to the [SEC], will receive credit for any information the company subsequently self-reports to the SEC.
The original article can be found at www.fcpablog.com