On May 25, 2011, the Securities and Exchange Commission adopted by a 3-2 vote final rules implementing the whistleblower program under Section 21F of the Securities Exchange Act of 1934 (the “Exchange Act”) as required by Section 922 of the Dodd- Frank Wall Street Reform and Consumer Protection Act (the “Dodd Frank Act”). The program authorizes the SEC to pay rewards to individuals who voluntarily provide the SEC with original information about a violation of the federal securities laws that leads to a successful enforcement action that results in monetary sanctions totaling more than $1 million. The total amount of the award is between 10% and 30% of the monetary sanctions. Although the SEC received a significant number of comments urging a requirement that a whistleblower is only eligible to receive an award if the whistleblower first reported the matter through the relevant entity’s internal compliance program, the SEC chose not to mandate internal reporting and instead provided additional protections and incentives to encourage individuals to report suspected violations internally. The final rules are effective 60 days following publication in the Federal Register, which has not yet occurred.