105
edits
Difference between revisions of "SEC Whistleblower Program"
→Rationale for Deeming Payments made under DPAs and NPAs as “Monetary Sanctions”
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This proposed addition to Rule 21F-4 sought to make awards available to meritorious whistleblowers in cases where these alternative vehicles are used to address violations of law. Its premise was the same as that underlying current Rule 21F-4(d)(1) — that Congress did not intend for meritorious whistleblowers to be denied awards simply because of the procedural vehicle that the SEC (or another governmental entity) has selected to resolve an enforcement matter. | This proposed addition to Rule 21F-4 sought to make awards available to meritorious whistleblowers in cases where these alternative vehicles are used to address violations of law. Its premise was the same as that underlying current Rule 21F-4(d)(1) — that Congress did not intend for meritorious whistleblowers to be denied awards simply because of the procedural vehicle that the SEC (or another governmental entity) has selected to resolve an enforcement matter. | ||
== Rationale for Deeming Payments made under DPAs and NPAs as “Monetary Sanctions” == | == '''Rationale for Deeming Payments made under DPAs and NPAs as “Monetary Sanctions”''' == | ||
The September 2020 SEC release adopting [https://www.sec.gov/rules/final/2020/34-89963.pdf amendments] to the rules governing the [https://www.zuckermanlaw.com/sp_faq/sec-whistleblower-program/ SEC Whistleblower Program] explains the rationale for deeming payments made under DPAs and NPAs as “monetary sanctions” on which an award can be based: | The September 2020 SEC release adopting [https://www.sec.gov/rules/final/2020/34-89963.pdf amendments] to the rules governing the [https://www.zuckermanlaw.com/sp_faq/sec-whistleblower-program/ SEC Whistleblower Program] explains the rationale for deeming payments made under DPAs and NPAs as “monetary sanctions” on which an award can be based: | ||