A divided Second Circuit panel has found that the whistleblower protection provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act extend to employees who file only internal complaints and do not report the alleged corporate wrongdoing to the Securities and Exchange Commission.
Setting up a split among the circuits, two judges of the U.S. Court of Appeals for the Second Circuit said Daniel Berman could pursue his claim that he was fired for making internal complaints about accounting procedures at Neo@Ogilvy, a subsidiary of WPP Group USA, Inc.
