"The SEC does not believe employees in such quasi-investigative roles obtain such information as a result of “independent knowledge or independent analysis” [17 C.F.R. 240.21F-4(b)(1)]."

"The third exception allows for whistleblower awards after more than120 days have passed since the employee disclosed allegations to the audit committee, chief legal officer, chief compliance officer or supervisor [17 C.F.R. 240.21F-4(b)(v)(C)]."

"The SEC’s first whistleblower award given to an employee performing audit and compliance functions was doled out in August 2014. It totaled $300,000 and concerned a company that had failed to respond to allegations of misconduct within the 120-day period."

" At the time, the SEC made the following statement: “This particular whistleblower award recipient reported concerns of wrongdoing to appropriate personnel within the company, including a supervisor…When the company took no action on the information within 120 days, the whistleblower reported the same information to the SEC.”

"The 120-day period is not a substantial amount time to investigate and respond to an inquiry, and the impending harm exception has no specified time limit. Accordingly, allegations of misconduct warrant immediate attention under either exception."

"And internal systems should (i) generate reports on the timing of receipt; (ii) send reminders to supervisors on need to respond by relevant deadlines; and (iii) send documentation to the information source that the matter is being addressed (to reduce the likelihood that a potential whistleblower might assert that no response was given by the company)."

120 / 30 = 4

12/9/2011 - 5/8/2012 =

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