In the post-#MeToo era, employers’ responses to internal complaints of wrongdoing are under increased scrutiny from every possible direction. This includes shareholders, consumers, the media, and, perhaps most important, government and regulatory authorities.
Seven short months ago, in January 2019, financial services employers woke up to learn of a new whistleblower program directive issued by the New York State Department of Financial Services (DFS). This set off an urgent scramble among New York-based banks, insurance companies, and other entities regulated by the DFS, to assure that their internal policies meet these new standards.
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