Whistleblower Award Determination

BSM Supervisão de Mercados, a Brazilian self-regulatory entity, submits comments supporting the CFTC's goal of improving whistleblower program efficiency and transparency. While they do not have a financial award program, they share their own reporting model and best practices to foster international dialogue on market integrity.

Better Markets, Inc. supports the proposed rule to establish a 30% award presumption for meritorious whistleblowers to improve efficiency and transparency. While they support the rule, they suggest the Commission consider a higher $15 million threshold to further reduce processing times.

A partner at the law firm Phillips & Cohen, LLP supports the Proposed Rule because it streamlines the award process for smaller cases and preserves resources for larger ones. However, the commenter suggests adding a provision to ensure that whistleblowers in cases exceeding the $5 million threshold do not receive smaller awards than those who fall under the new presumption.

The commenter opposes the proposed whistleblower award program, arguing that monetary incentives may encourage fraudulent claims and the targeting of political opponents. They suggest that the government should focus on creating rules to protect whistleblowers based on moral decency rather than providing financial rewards.