It is not the first whistleblower award under the Dodd Frank Act’s whistleblower bounty program but the “more than $14 million” award to an anonymous whistleblower that the SEC announced on October 1, 2013 is by far the largest so far...
by Elana Hahn, Kenneth Kohler, Nimesh
Christie and Melissa Beck
This EIA is a guide to the
principal EU and US securitization regulatory developments and the challenges
and prospects for transatlantic securitization issuers and investors.
The Dodd-Frank Wall Street Reform and Consumer Protection
Act is a sprawling piece of legislation. It is also very much a work in
progress, requiring hundreds of new rules to be written and dozens of studies.
The burden imposed on the SEC is considerable...
Title II of the Dodd-Frank Wall Street Reform and
Consumer Protection Act, H.R. 4173, 111th Cong. (2010) (the "Dodd-Frank Act" or
the "Act"), titled "Orderly Liquidation Authority," creates a new federal
Although nearly everyone - including the five SEC
commissioners - agrees that corporate whistleblowers are the best source for
detecting corporate fraud, there is trepidation about the proposed
whistleblower bounty program under the Dodd-Frank Act...
by Robert J. Pile, Jennifer D. Lambert, and Heather J.
Third-party service providers to financial institutions
have often taken the position that they are not "financial institutions" for
purposes of federal law and thus are typically...
by Fred Bellamy, Jamie Cain, Tom Gick, Steve
Roth, and Ann Battle
In addition to requiring the Commodity Futures Trading
Commission (the CFTC) and the Securities and Exchange Commission (the SEC) to
promulgate rules further defining the terms "swap"...
Dodd-Frank added Exchange Act Section
21F(g)(5) and requires that SEC's Office of the Whistleblower to report to Congress
annually on the whistleblower program. It's due each October 30. I'm sure the
SEC wanted to be in compliance, so they...
In the week ending with "April Fools Day," the Commission
continued to issue proposed regulations to implement the Dodd-Frank Wall Street
and Consumer Protection Act. SEC Enforcement focused on investment fund fraud
actions, filing or resolving...
Financial reform and the implementing Dodd-Frank continue
to be key topics for market regulators. The SEC, CFTC and others are busy
writing rules to implement the Act. Many on Capital Hill are studying ways to
limits or repeal portions of the landmark...
The Securities and Exchange Commission proposed a new
rule that would require advisers to private funds to report information for use
by the Financial Stability Oversight Council in monitoring risk to the U.S.
financial system. Sections 404
The focus of SEC enforcement in the coming months is a
function of its constricted and later expanded authority. Last year that
authority contracted in the wake of the Supreme Court's decision in Morrison
v. National Australia Bank Ltd. , 130 S...
Previously, I summarized the Securities and Exchange Commission’s implementing regulations of Title II of the JOBS Act , lifting the ban on general solicitation for offerings exempt under Rule 506 of Regulation D, which were finalized on July 10...
Dodd-Frank significantly added to the weapons available
to the SEC. New provisions extended its authority to bring actions based on
aiding and abetting while lowering the proof requirements to recklessness.
Collateral bars were added and a provision...
by Gary Larkin
As you all may well know by now, the SEC has adopted its
final rules to create a whistleblower bounty program as part of the Dodd-Frank
Act by a familiar 3-2 split vote. The rules, which go into effect 60 days after
they are submitted...