Even thought the SEC’s final regulations for the Dodd-Frank whistleblower program just became effective on August 12, 2011, the agency has already filed its first report on the whistleblower program. During the first seven weeks of the program, the agency received 334 whistleblower tips.
The SEC itself cautions that “due to the relatively recent launch of the program and the small sample size, it is too early to identify any specific trends or conclusions from the data collected to date.”
A surprising number of the reports originated outside the United States. The country with the highest number of submissions was China (10),followed by the U.K. (9). Whistleblower submissions reporting FCPA violations represented only four percent of the submissions during the reporting period, a level of submissions that has puzzled some commentators. (SEC Releases Initial Report on the Dodd-Frank Whistleblower Program, The D&O Diary, 11/18/2011)
Appendix A lists, by subject matter and month, the 334 whistleblower tips received from August 12, 2011 through September 30, 2011. The most common complaint categories were market manipulation (16.2%), corporate disclosures and financial statements (15.3%), and offering fraud (15.6%).