SEC Proposed Rules for Whistleblower Program

November 5, 2010

On November 3, 2010, the SEC voted unanimously to propose rules governing its whistleblower program to reward individuals who provide the agency with high quality tips that lead to successful enforcement actions. The proposed rules are intended to implement Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under the proposed program, a whistleblower who provides information about any potential securities law violation may be entitled to receive a bounty totaling 10 to 30% of the aggregate penalties obtained in an SEC enforcement action. The comment period for the proposed rules ends on December 17, 2010. Under the Dodd-Frank Act, final rules must be implemented by April 2011. The attached memorandum summarizes the key provisions in the proposed rules.