SEC WHISTLEBLOWER PROGRAM

SEC WHISTLEBLOWER APPLICATIONS DENIED TO DATE

The truth is, of the 7,000 or so submissions the SEC receives each year, the lion’s share never even make it to an investigative team. (Sidebar: our submissions usually do.) Nearly half of those denials didn’t make the cut because the submissions didn’t follow the program rules.

This keeps us awake at night.

SEC Whistleblower Awards to Date Key Considerations

Eligibility Requirements

Date	Description	Denial Justification	Key Docs
6/26/2021	Claimant's information was never provided to or used by SEC staff in the investigation or resulting Covered Action. Claimant also failed to comply with program requirements for tip submission.	Form and Manner of Submission/Application Did Not Comply With Program Rules Information Did Not Lead to the Successful Enforcement Action	Order
6/25/2021	Claimant did not provide any independent analysis. The tip consisted only of Claimant pointing out purported "red flags" in publicly available information on a firm's website.	Not Original Information	Order
6/21/2021	The SEC did not specify a reason for its denials of three Claimants' applications. It merely noted the denials and Claimants' non-appeals, in an Order providing an award to another Claimant.	None Disclosed	Order
6/21/2021	Claimant's information was never provided to or used by SEC staff in the investigation or resulting Covered Action.	Information Did Not Lead to the Successful Enforcement Action	Order
6/21/2021	Claimant's award application was denied - regardless of whether the SEC had mishandled reported information - because "the standard for award eligibility is not what the staff would have, or could have done in hypothetical circumstances but, rather, what impact the whistleblower's tip actually had on the investigation."	Information Did Not Lead to the Successful Enforcement Action	Order
6/13/2021	Claimant's information was never provided to or used by SEC staff in the investigation or resulting Covered Action.		Order
6/13/2021	Claimant's information was never provided to or used by SEC staff in the investigation or resulting Covered Action.	Information Did Not Lead to the Successful Enforcement Action	Order
6/13/2021	Claimant's information was never provided to or used by SEC staff in the investigation or resulting Covered Action.	Information Did Not Lead to the Successful Enforcement Action	Order
6/13/2021	Claimant's information was never provided to or used by SEC staff in the investigation or resulting Covered Action.	Information Did Not Lead to the Successful Enforcement Action	Order
6/13/2021	Claimant's information was never provided to or used by SEC staff in the investigation or resulting Covered Action.	Information Did Not Lead to the Successful Enforcement Action	Order