The U.S. Securities and Exchange Commission’s whistleblower program has taken off since its creation in 2010 from the Dodd-Frank financial reforms, awarding more than $150 million in bounties to tipsters who have helped the agency bring successful enforcement actions. Last year, the SEC’s enforcement director at the time, Andrew Ceresney, called the whistleblower office a “game changer” for the agency.

But as that office has doled out awards and taken steps to protect whistleblowers, a question has loomed large over the agency: To be eligible for the anti-retaliation protections embedded in Dodd-Frank, must a corporate insider contact the SEC or is it enough to only report internally to an employer?

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