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Despite the controversy over the SEC program and issue of whether employees arebeing encouraged to bypass internal reporting mechanisms, the SEC 2014 AnnualReport on the whistleblower program, SEC press releases on whistleblower awards,and SEC representatives speaking at conferences have emphasized that a significantnumber of awards to date involve instances where suspected wrongdoing was initiallyreported internally by individuals who ultimately became whistleblowers.Thiscircumstance comports with the experience of many counsel involved in theinvestigation and defense of whistleblower claims, and suggests again that somecorporate compliance programs and mechanisms intended to allow for the identificationand correction of problems are not working.While the SEC whistleblower program under Dodd-Frank is still in its infancy, andprogram rewards are only available for reported violations of federal securities laws, thelevel of reporting to SEC and the SEC’s stated intention to further intensify itsenforcement efforts suggest that there will be more Dodd-Frank whistleblower actiongoing forward.C. Internal Revenue Service Whistleblower ProgramThe Internal Revenue Service (“IRS”) also has a whistleblower program which wasestablished in 2007 and operates under the IRS Whistleblower Office which wascreated by the Tax Relief and Health Care Act of 2006. 2929Whistleblower Office At-a-Glance, http://www.irs.gov/uac/Whistleblower-Office-At-a-Glance (LastReviewed or Updated Mar. 7, 2014).11