Last month, the Securities and Exchange Commission adopted final rules to implement the whistleblower provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). Dodd-Frank created a new Section 21F of the Securities Exchange Act of 1934 (the “Exchange Act”), which establishes a whistleblower program requiring the SEC to pay an award of between 10 and 30 percent of monetary sanctions aggregating at least $1,000,000 to eligible whistleblowers who voluntarily provide the SEC with original information about a violation of the federal securities laws. Section 21F of the Exchange Act also prohibits retaliation by employers against individuals who provide the SEC with information about possible securities violations. Significantly, despite many commentators’ objections, the final rules do not require whistleblowers to report potential securities law violations through a company’s internal compliance program as a prerequisite to an award. The final rules, which apply to both public and private companies, will be effective on August 12, 2011.