The new SEC Whistleblower program has been receiving a continuous volume of complaints since the program began in August 2011. In the first two months alone, the SEC whistleblower program received 334 complaints (an average of 7 per day) and according to the SEC, since that time frame, the volume has continued to be steady.
The SEC is also reporting that in nearly all of the whistleblower complaints they have received, the whistleblowers have notified their employer's internal compliance program of their claims.
The SEC Whistleblower rules effectively create a 120-day window for companies to address internal whistleblower claims. Therefore, it is critical that companies become aware of the extent of their exposure or liability from a whistleblower claim within the 120-day window so that they may make an educated judgment on whether they should self-report, or whether they are required to modify their financial statements or otherwise make a filing or submission. This information is also critical to making a determination about what actions the company may legally take against the whistleblower should a performance based action or disciplinary measure be warranted. Be prepared for claims.
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Hear former SEC Inspector General Kotz discuss timely best practices for complying with the SEC's new whistleblower program.
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Confidently draft business policies that dictate steps to take when a whistleblower comes forward.
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Understand a company's exposure to liability when an internal whistleblower claim is addressed.
Who Should Attend?
This up to date legal briefing is designed for attorneys.
Course Content:
The former SEC Inspector General will discuss:
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How to Respond Appropriately When a Whistleblower Comes Forward
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How and When to Communicate With the SEC or Other Federal Agency to Minimize Exposure and Liability
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How the SEC Views Whistleblowers and How to Navigate the New Whistleblower Program
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