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“I think that it will be significant, because one of the ways that whistleblower programs establish trust with potential whistleblowers is when they make payments,” said Jordan Thomas, a former SEC official who oversaw the creation of the whistleblower program and who now represents whistleblowers at the [prior firm] in New York. “It’s going to be a significant event,” Thomas said. “For those few companies who have not reevaluated their internal reporting systems, this will be a wake-up call.”