The rule states that officers, directors, trustees, and partners are ineligible for the award if they learn about the alleged fraud event when another employee reports it to the company. But according to the SEC, “There is an exception to this exclusion that makes an officer eligible if he or she reports the information to the SEC more than 120 days after other responsible compliance personnel possessed the information and failed to adequately address the issue.”  

The officer reported a securities law violation when he or she realized the company’s internal controls had failed to address it.  

Read the SEC’s full press release at        

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