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Section 924(d) of the Dodd-Frank Act requires the Securities and Exchange Commission’s (SEC) Office of the Whistleblower to report annually to Congress on whistleblower complaints and its responses. In November 2011, the SEC issued its inaugural annual report on the Dodd-Frank Whistleblower Program. Because the final rules implementing the Dodd-Frank Act did not become effective until Aug. 12, 2011 and the SEC’s fiscal year ended Sept. 30, 2011, the report includes only seven weeks of data describing just 334 whistleblower submissions. Despite the small sample, the report offers a significant takeaway for corporations: internal reporting and compliance programs matter.

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