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
10/25/2020	Five (5) Claimants were denied awards. Two did not appeal. The information from one of the three remaining Claimants was “not compelling enough.” Likewise, the information from the remaining two Claimants concerned conduct that was not charged.	Information Did Not Lead to the Successful Enforcement Action	Order
10/13/2020	The “Covered Action staff” did not communicate with or receive information from Claimant, whose tips did not concern the relevant factual or legal issues.	Information Did Not Lead to the Successful Enforcement Action	Order
10/09/2020	The SEC’s investigation was ongoing when it received Claimants’ tips, which were unrelated to the resulting Covered Action.	Information Did Not Lead to the Successful Enforcement Action	Order
10/09/2020	The information reported by Complainant was not relevant and/or was already known to the SEC.	Information Did Not Lead to the Successful Enforcement Action Not Original Information	Order
10/05/2020	The SEC found that the information provided by Complainant concerned conduct in countries that were not relevant in the Covered Action.	Information Did Not Lead to the Successful Enforcement Action	Order
10/02/2020	The SEC’s Office of Market Intelligence marked Claimant’s tip “No Further Action.” This often means that the information did not relate to a securities violation.	Information Did Not Lead to the Successful Enforcement Action	Order
9/30/2020	The SEC did not specify a reason for the denials of awards to two Claimants, who did not appeal.	None Disclosed	Order
9/30/2020	The SEC did not specify a reason for the denials of two Claimants’ applications. It merely noted the denials and Claimants’ non-appeals, in an Order providing an award to a different Claimant.	None Disclosed	Order
9/29/2020	SEC staff had already begun investigating when Claimant submitted their tip, and the information did not advance that.	Information Did Not Lead to the Successful Enforcement Action	Order
9/28/2020	The Covered Action had already been filed when Claimant submitted his/her information, which was already known to the Commission.	Information Did Not Lead to the Successful Enforcement Action Not Original Information	Order