2021-04-09 SEC Press pdf 275 KB 2,606 chars

In the Matter of the Claim for an Award

summary

The SEC awarded a whistleblower approximately $2.5 million—representing a percentage of monetary sanctions—for providing original, credible information that led to an enforcement action against a party for breaching fiduciary duties to investors, after voluntarily reporting internally and providing substantial ongoing assistance.

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The SEC awarded a whistleblower approximately $2.5 million, representing a percentage of monetary sanctions collected or to be collected in a single covered action involving a breach of fiduciary duty to investors. The whistleblower voluntarily reported the misconduct internally before contacting the SEC and provided critical ongoing assistance, including testimony and documentation, which enabled the Commission to pursue enforcement. The Commission treated related judicial and administrative actions as one covered action under Rule 21F-4(d)(1), and no other claimants contested their denials, allowing the Preliminary Determination to become final.

narrative

The SEC awarded a whistleblower approximately $2.5 million, representing a percentage of monetary sanctions collected or to be collected in a covered action involving a breach of fiduciary duty owed to investors. The whistleblower voluntarily reported the misconduct internally before providing original, credible information to the Commission, which directly led to the successful enforcement action. The whistleblower provided substantial ongoing assistance, including meetings, testimony, and documentation that were key to the case. The Commission treated related judicial and administrative actions as a single covered action under Rule 21F-4(d)(1), consolidating sanctions for award purposes. The award was justified based on the significance of the information, the law enforcement interest in stopping ongoing securities violations, and the whistleblower’s cooperation. No other claimants sought reconsideration of their denials, and the whistleblower did not contest the Preliminary Determination, resulting in its adoption as final. The exact percentage of the award and the identity of the respondent remain redacted.

Enriched metadata

Scheme
investment-adviser-fraud (80%)
Victim loss
$2,500,000
Classified investment-adviser-fraud(confidence 80%). EDGAR detection: forms ADV/ADV-E/ADV-W/Form D· recall 33% / precision 13%. detection rule →
Statutes
15 U.S.C. § 78u-6(b)17 C.F.R. § 240.21F-4(d)17 C.F.R. § 240.21F-3(a)Rule 21F-4(d)Rule 21F-10Rule 21F-3(a)
Parties
claims review staffcompanyoriginal information to sec leading to successful enforcementsecretary of secsec to bring action against defendant for breach of fiduciary dutySecurities and Exchange Commission
Keywords
redacted redactedredactedclaimantawardcovered actionexchangecommissionclaim awardsecurities exchangewhistleblower awardpreliminary determinationclaimactionmattersecurities

Extracted insights

Dollar amounts 1
  • $2.50M $2.5 million $1M–$10M
Entities 6
  • person claims review staff
  • company company
  • agency original information to sec leading to successful enforcement
  • agency secretary of sec
  • agency sec to bring action against defendant for breach of fiduciary duty
  • agency Securities and Exchange Commission
Triples 9
  • Claimant receive Whistleblower Award Of Approximately $2.5 Million
  • Claims Review Staff issued Preliminary Determination Recommending Whistleblower Award
  • Claimant provided Original Information To SEC Leading To Successful Enforcement
  • SEC adopted Recommendation Of Claims Review Staff
  • Claimant reported internally to Company
  • Claimant provided Significant Ongoing Assistance To Enforcement Staff
  • Claimant's Information allowed SEC To Bring Action Against Defendant For Breach Of Fiduciary Duty
  • SEC issued Securities Exchange Act Release No. 91520 On April 9, 2021
  • Vanessa A. Countryman signed as Secretary Of SEC
Text layers
Extracted body text (2,606c)

 
  
UNITED STATES OF AMERICA 
before the 
SECURITIES AND EXCHANGE COMMISSION 
SECURITIES EXCHANGE ACT OF 1934 
Release No. 91520 / April 9, 2021 
WHISTLEBLOWER AWARD PROCEEDING 
F
ile No. 2021  37 
In the Mat
ter of the Claim for an Award 
in connection with 
Notice of Covered Action 
Redacted
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ORDER DETERMINING WHISTLEBLOWER AWARD CLAIM 
The Claims Review Staff (“CRS”) issued a Preliminary Determination recommending 
that (“Claimant”) receive a whistleblower award in the amount of approximately 
$2.5 million, which equals percent (    %) of the monetary sanctions collected, or to be 
collected, in 
1 
Claimant provided written notice stating that Claimant will not contest the 
Preliminary Determination.
2
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The recommendation of the CRS is adopted. The record demonstrates that Claimant 
voluntarily provided original information to the Commission that led to the successful 
enforcement of the Covered Action.
3
1 
For the purposes of making an award, we determined to treat the judicial and administrative actions in this matter 
as a single Covered Action because they arose out the same nucleus of operative facts. See Securities Exchange Act 
of 1934 (“Exchange Act”) Rule 21F-4(d)(1), 17 C.F.R. § 240.21F-4(d)(1). 
2 
An additional claimant on the matter did not seek reconsideration of their denial and, as such, the Preliminary 
Determination with respect to their claim became the Final Order of the Commission, pursuant to Exchange Act 
Rule 21F-10. 
3 
See Exchange Act Section 21F(b)(1), 15 U.S.C. § 78u-6(b)(1); Rule 21F-3(a), 17 C.F.R. § 240.21F-3(a). 

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In reaching this determination, the Commission considered that: (i) Claimant provided 
significant ongoing assistance to Enforcement staff, including by meeting with and providing
RedactedRedacted
 key to Enforcement staff in support of the case; (ii) there is 
substantial law enforcement interest here as Claimant’s information allowed the Commission to 
bring an action against
Redacted
 engaging in an ongoing violation of the federal 
securities laws relating to the breach of fiduciary duty owed to investors; and (iii) Claimant 
reported internally to the company. 
Accordingly, it is hereby ORDERED that Claimant shall receive an award of 
***
percent ( 
***
%) of the monetary sanctions collected, or to be collected, in the Covered Action. 
By the Commission. 
Vanessa A. Countryman 
Secretary 
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OCR text (2,634c · tika · 95% conf)
UNITED STATES OF AMERICA 
before the 

SECURITIES AND EXCHANGE COMMISSION 

SECURITIES EXCHANGE ACT OF 1934 
Release No. 91520 / April 9, 2021 

WHISTLEBLOWER AWARD PROCEEDING 
File No. 2021 37 

In the Matter of the Claim for an Award 

in connection with 

Notice of Covered Action 

Redacted

Redacted

Redacted

ORDER DETERMINING WHISTLEBLOWER AWARD CLAIM 

The Claims Review Staff (“CRS”) issued a Preliminary Determination recommending 
that (“Claimant”) receive a whistleblower award in the amount of approximately 
$2.5 million, which equals  percent ( %) of the monetary sanctions collected, or to be 
collected, in 

1 Claimant provided written notice stating that Claimant will not contest the 
Preliminary Determination.2

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*** ***

The recommendation of the CRS is adopted. The record demonstrates that Claimant 
voluntarily provided original information to the Commission that led to the successful 
enforcement of the Covered Action.3

1 For the purposes of making an award, we determined to treat the judicial and administrative actions in this matter 
as a single Covered Action because they arose out the same nucleus of operative facts. See Securities Exchange Act 
of 1934 (“Exchange Act”) Rule 21F-4(d)(1), 17 C.F.R. § 240.21F-4(d)(1). 

2 An additional claimant on the matter did not seek reconsideration of their denial and, as such, the Preliminary 
Determination with respect to their claim became the Final Order of the Commission, pursuant to Exchange Act 
Rule 21F-10. 

3 See Exchange Act Section 21F(b)(1), 15 U.S.C. § 78u-6(b)(1); Rule 21F-3(a), 17 C.F.R. § 240.21F-3(a). 



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In reaching this determination, the Commission considered that: (i) Claimant provided 
significant ongoing assistance to Enforcement staff, including by meeting with and providing

Redacted Redacted key  to Enforcement staff in support of the case; (ii) there is 
substantial law enforcement interest here as Claimant’s information allowed the Commission to 
bring an action against Redacted  engaging in an ongoing violation of the federal 
securities laws relating to the breach of fiduciary duty owed to investors; and (iii) Claimant 
reported internally to the company. 

Accordingly, it is hereby ORDERED that Claimant shall receive an award of ***

percent ( *** %) of the monetary sanctions collected, or to be collected, in the Covered Action. 

By the Commission. 

Vanessa A. Countryman 
Secretary 

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