On November 16, the SEC released its 2015 annual report to Congress on the Dodd-Frank Whistleblower Program, which offers rewards to persons who provide information to the SEC that leads to successful enforcement actions. The report shows significant increases in tips received under the Program. The report also provides important guidance to companies on the SEC's whistleblower-related priorities through fiscal year 2016. According to WilmerHale's client alert, four themes emerged from the report:
- Whistleblower tips continue to rise
- Complaints of corporate disclosure and financial reporting fraud are up
- Protection for internal reports remains a key focus area
- Continued focus on confidentiality agreements should be expected