Comments on Proposed SEC Whistleblower Rules

In the rule-making process, the SEC reviewed a voluminous amount of commentary on the proposed whistleblower program.  Some of these comments can be viewed here. Many of these letters represented the views of a vast number of major public companies, which were concerned, among other things, that the program would undermine internal compliance systems.  See an example here of a letter submitted on behalf of Apache Corporation; Cardinal Health, Inc.; The Goodyear Tire & Rubber Company; Hewlett-Packard Company; Merck & Co., Inc.; Microsoft Corporation; Newmont Mining Corporation; Procter & Gamble Co.; TRW Automotive Holdings Corp.; and United Technologies Corporation.