SEC Adopts Final Whistleblower Rules

May 27, 2011
The U.S. Securities and Exchange Commission’s belated adoption of final whistleblower rules pursuant to Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act in a divided vote on May 25 has done little to temper the sharply divided opinions on various aspects of the rules. Most significantly, the decision not to require would-be whistleblowers to report potential securities violations within a company before reporting externally to the SEC poses significant challenges for in-house legal and compliance departments. In this update, we review the key provisions and implications of the new rules.