October 11, 2019
Dear Rule Comments, I am writing to urge you to reach out to the U.S. Securities and Exchange Commission (SEC) about proposed changes to its extremely successful whistleblower program. Whistleblowers have helped the SEC recover over $1.7 billion in sanctions from wrongdoers over the past decade. As your constituent, issues of accountability are extremely important to me. Proposed revisions to Exchange Act Rule 21F-9(e) would create an unrealistic reporting procedure that would unfairly disqualify a vast number of whistleblowers. Proposed revisions to Exchange Act Rule 21F-6 would also disincentivize whistleblowers from coming forward by placing an arbitrary limit on whistleblower rewards. I urge you to stand in opposition to these proposed changes by the SEC and help ensure its robust whistleblower program continues. If you have any questions about the proposed SEC amendments or would like more information about them, please contact the National Whistleblower Center at info@whistleblowers.org. If you have questions about the international human rights implications of these proposed SEC changes please contact me at medicalwhistleblower@gmail.com. I, Janet Parker, from Medical Whistleblower Advocacy Network, act as a Human Rights Defender in the UPR process, the OAS-IACHR, and consultation with the United Nations associated Committees. Medical Whistleblower Advocacy Network supports the United Nations Guiding Principles on Business and Human Rights and their implementation through national action plans. Medical Whistleblower Advocacy Network was consulted for the discussion for the 3rd Session of the Open-ended Intergovernmental Working Group on Transnational Corporations and other Business Enterprises with respect to human rights ( Oct. 23 to 27,2017 Palais des Nations Room XX, Geneva, Switzerland.) As a Human Rights Defender who has provided the United Nations information about transnational corporations and human rights violations, I want to emphasize that SEC Whistleblowers critically need protection and incentives to come forward with essential intelligence about corporate policy decisions which impact human rights. SEC whistleblowers are critical to the ability to monitor criminal activities like money laundering which goes hand in hand with criminal activities such as human trafficking and medical fraud. This new proposed rule change by the Securities and Exhange Commission (SEC) would discourage whistleblowers from coming forwards and also discourage qualified attorneys from taking these cases which are very legally complex and require multiple court filings and are financially expensive to pursue. In addition, when blowing the whistle on a large corporation which is involved in criminal behavior, the whistleblower may also be in significant danger of harm to himself, his professional reputation and his family. I urge you to stand in opposition to these proposed changes by the SEC and help ensure its robust whistleblower program continues. Sincerely, Janet Parker [redacted]