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Those rules have served to greatly increase reporting of potential corporate wrongdoingto the SEC with approximately 3000 tips being made a year.The Dodd-Frank whistleblower program, operated by SEC for three years, hasgenerated thousands of tips or reports of suspected wrongdoing but only 14 awardsthrough the end of 2014, suggesting that the SEC enforcement staff is being cautiousand selective in connection with the whistleblower reports they elect to investigate. 22 Onthe other hand, considering the time typically required for the investigation of significantviolations of the securities laws, the handful of awards made to date may be just the tipof a coming wave of whistleblower inspired SEC enforcement actions. Indeed, SECand other governmental representatives (speaking at conferences and only on their ownbehalf) continue to suggest that is the case. 23 Given that the SEC’s Investor ProtectionFund, the fund containing monies available for award to qualifying whistleblowers,contains nearly $440 million as of the end of fiscal 2014, there may be something tothese predictions. 24The Dodd-Frank whistleblower program has been criticized for encouraging employeesto report suspected violations without first resorting to internal reporting and relatedcompliance procedures. The SEC has attempted to address this concern by indicatingthat it will award credit to whistleblowers who previously or simultaneously reported theirconcerns to company authorities. However, SEC whistleblower awards are not22 See SEC Whistleblower Program Information at https://www.sec.gov/whistleblower; See SEC StaffAnnual Report to Congress on the Dodd-Frank Whistleblower Program (Nov. 17, 2014), available athttp://www.sec.gov/about/offices/owb/annual-report-2014.pdf.23 See e.g., Remarks at 31st International Conference on the Foreign Corrupt Practices Act, AndrewCeresney, Director, SEC Division of Enforcement (Nov. 19, 2014).24 SEC Staff Annual Report to Congress on the Dodd-Frank Whistleblower Program (Nov. 17, 2014),available at http://www.sec.gov/about/offices/owb/annual-report-2014.pdf.9