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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.

Date Description Denial Justification Key Docs
3/17/2021 Claimant did not voluntarily report and thus was ineligible for a whistleblower award. The SEC or another regulatory authority had previously made a request, inquiry or demand into the subject matter.
  • Information Did Not Lead to the Successful Enforcement Action
  • Information Not Voluntarily Provided
3/04/2021 Ten (10) Claimants were denied an award. Eight of them did not appeal. The tips from the remaining two Claimants only concerned conduct by competitors of the relevant company, and did not contribute to the Covered Action.
  • Information Did Not Lead to the Successful Enforcement Action
2/19/2021 Claimant, in his/her multiple award applications, fatally did not refer to a Covered Action brought by the SEC. It appears Claimant’s tips concerned conduct that was the subject of enforcement action by other federal agencies only.
  • Ineligible Applicant
2/19/2021 The SEC did not specify a reason for its denial of this Claimant's application. It merely noted the denial and Claimant’s non-appeal, in an Order providing an award to a different Claimant.
  • None Disclosed
2/19/2021 The SEC did not specify a reason for the denials of awards to two Claimants, who did not appeal.
  • None Disclosed
2/12/2021 Claimant’s information had previously been reported by the relevant company and thus was already known to the SEC. It appears Claimant internally reported first but did not subsequently report to the SEC within the “safe harbor” of 120 days.
  • Form and Manner of Submission/Application Did Not Comply With Program Rules
  • Information Did Not Lead to the Successful Enforcement Action
  • Not Original Information
1/25/2021 The SEC found that its investigative staff never communicated with or received any information from these two Claimants.
  • Information Did Not Lead to the Successful Enforcement Action
1/22/2021 The SEC found that Claimant’s information was only reviewed during the course of a separate investigation and did not contribute to the success of the Covered Action
  • Information Did Not Lead to the Successful Enforcement Action
1/14/2021 Award denied to Claimant whose tip had no nexus to and no allegations concerning the Respondents charged in the Covered Action.
  • Information Did Not Lead to the Successful Enforcement Action
1/13/2021 According to the SEC’s Order, Claimants information was vague, inferior to information already in the agency’s possession, and not utilized in the Covered Action.
  • Information Did Not Lead to the Successful Enforcement Action
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