SEC doles out minimal benefit to cooperator - .PDF file.
Since the enactment of Dodd-Frank, there has been a great deal of focus on rewards for ‘whistleblowing’ — bringing to the government’s attention evidence of wrongdoing that it did not previously know about. Yet a much more common question is how much credit to give wrongdoers who are first approached by investigators, but who could still help them make a fast, easy case against others, if the government made it worth their while. In a recent insider trading action, SEC v Wrangell, the SEC announced that it had rewarded this type of cooperator, but the amount of the reward appears inadequate to induce widespread cooperation.
Click on the link above to download this Covington & Burling briefing.