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"It's all in the footnotes: A field guide to SEC whistleblower awards" (Part 2 of 5) by Christopher F. Regan, Matthew E. Newman, and Ian J. Acker (Business Law Today)

Business Law Today

Christopher F. Regan

Part Two of this five-part series will continue to examine the question of who qualifies for SEC whistleblower awards.

Who Qualifies for an SEC Whistleblower Award? (Cont.)

5. Special Timing Issues

a. Eligibility Begins After July 21, 2010

In many cases, an individual who provided information to the SEC prior to the enactment of Dodd-Frank has attempted to claim an award under the whistleblower program. However, as mentioned above, the whistleblower rules deem a submission to be “original information” only if it was “[p]rovided to the [SEC] for the first time after July 21, 2010 (the date of enactment of [Dodd-Frank]).”  This eligibility start-date rule can make or break awards, even for committed whistleblowers.

Click here to read Part 2 of the article.

Click here to read the full article.

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