Much attention has been given to the whistleblower protections of Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. That section, effective immediately on enactment, expanded whistleblower protections and created a private right of action for employees of publicly traded companies under the Sarbanes-Oxley Act of 2002. In addition, Section 929A of Dodd-Frank confirmed that SOX protections were available to employees of subsidiaries and affiliates of public companies as well as the public companies themselves.
What has gone largely unnoticed, however, is Section 1057 of Title X of Dodd-Frank, which extends whistleblower protections to nonpublic providers of consumer financial services. Section 1057 will become effective on July 21, 2011.
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