The New Dodd-Frank Whistleblower Program Takes Shape as the Securities and Exchange Commission Releases Proposed Rules

November 23, 2010
The SEC’s recently proposed rules clarify to some degree whether and to what extent the new statutory scheme undercuts existing compliance programs, and address concerns regarding the propriety of allowing those charged with implementing internal compliance programs to become whistleblowers themselves, and of allowing employees who have engaged in wrongdoing to recover for whistleblowing.