Applying Whistleblower

2012 Webinar - Applying Whistleblower Rules at Investment Adviser Firms

Applying Whistleblower Rules at Investment Adviser Firms
Thursday, May 3, 2012, 1:00 pm - 2:15 pm ET

The SEC has established a Whistleblower Program pursuant to the Dodd-Frank Act that mandates that the SEC award payments to whistleblowers that voluntarily provide the SEC original information of securities law violation(s) leading to enforcement action and penalties collected of over $1 million. This panel will discuss considerations in implementing a whistleblower program at investment advisers and other ideas for meeting the requirements of the program at an advisory firm, including:

  • Adopting policies and procedures
  • Risk management including risk identification and mitigation
  • Training
  • Employment law considerations
  • Considerations in dealing with the SEC, a firm's employees, and bad actors

Stephen H. Bier is a partner in Dechert LLP in New York City. He represents investment advisers and registered open-end and closed-end investment companies and their boards of directors in a variety of matters including the development of new investment products and strategies, transactional issues, regulatory guidance, and compliance matters. He is a speaker on whistleblower issues for asset managers. He graduated from Rutgers College magna cum laude and from Harvard Law School, cum laude.

Lisa Sheeler is a Vice President and Assistant General Counsel at MFS Investment Management in Boston, where she focuses on the institutional investment advisory business, separately managed account programs, registered and unregistered funds and general corporate issues. Prior to joining MFS, she was an attorney at Fidelity Investments and Scudder Kemper Investments, as well as Seward & Kissel. She is a graduate of Boston University School of Law and Georgetown University.

John O'Neill is Director and Counsel for Affiliated Managers Group, Inc. where he works on legal and compliance matters relating to the firms affiliates. He has worked for Deloitte & Touche LLP developing and implementing for clients regulatory and portfolio compliance programs and internal controls. He has been an attorney at the law firm Monahan & Associates, P.C., as well as with Gargiulo, Rudnick & Gargiulo. Mr. O'Neill received a J.D. from Suffolk University Law School and a B.A. from College of the Holy Cross.

Paul D. Glenn (Moderator) is Special Counsel at the IAA. He worked for 12 years at the US Securities and Exchange Commission as a trial attorney and special counsel in the Division of Enforcement and the Office of General Counsel, respectively. Mr. Glenn also worked at the Office of the Comptroller of the Currency (OTS), as Deputy Chief Counsel and Special Counsel. He also worked at PNC Bank N.A. in Washington, DC, (formerly Riggs) and Millennium Bank N.A. in Reston, VA. He earned his LL.M from Georgetown University Law Center; his J.D. and B.A. from Case Western Reserve University; and an honorary doctor of laws degree from Nyack College.


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