CCB Whistleblower & Hotline Management 2 — Questions and Answers
Question 1: Under the Dodd-Frank Act, what is the minimum percentage of sanctions a whistleblower must qualify for to receive an award from the SEC?
- 5%
- 10% (Correct answer)
- 15%
- 20%
Correct answer: 10%
Dodd-Frank provides whistleblower awards between 10% and 30% of sanctions collected when violations exceed $1 million.
Question 2: Which federal law specifically protects employees of publicly traded companies who report securities violations from retaliation?
- False Claims Act
- Sarbanes-Oxley Act Section 806 (Correct answer)
- OSHA Section 11(c)
- National Labor Relations Act
Correct answer: Sarbanes-Oxley Act Section 806
SOX Section 806 prohibits publicly traded company employers from retaliating against employees who report securities law violations.
Question 3: A hotline caller reports misconduct anonymously but leaves enough detail to identify themselves. What is the compliance officer's primary obligation?
- Immediately disclose the identity to management
- Treat the report as confidential and protect the reporter's identity (Correct answer)
- Dismiss the report since anonymity was compromised
- Transfer the case to HR without noting the identity
Correct answer: Treat the report as confidential and protect the reporter's identity
Even when a reporter's identity can be inferred, the compliance function must safeguard that information and treat the report as confidential.
Question 4: What hotline metric best indicates whether employees trust the reporting channel?
- Total call volume per quarter
- Percentage of substantiated reports
- Ratio of anonymous to identified reports (Correct answer)
- Average call handle time
Correct answer: Ratio of anonymous to identified reports
A high ratio of anonymous reports relative to identified ones signals low trust; a shift toward identified reports typically reflects growing confidence in non-retaliation.
Question 5: Which entity administers the whistleblower award program under the Commodity Exchange Act?
- SEC
- DOJ
- CFTC (Correct answer)
- FinCEN
Correct answer: CFTC
The Commodity Futures Trading Commission (CFTC) operates its own whistleblower program under the Commodity Exchange Act, parallel to the SEC program.
Question 6: An employee files an internal hotline report and then, one week later, files an SEC tip. Which protection regime applies to retaliation that occurs after the SEC filing?
- Only SOX Section 806
- Only Dodd-Frank anti-retaliation provisions
- Both SOX and Dodd-Frank may apply depending on the facts (Correct answer)
- Neither, because the employee already used the internal channel
Correct answer: Both SOX and Dodd-Frank may apply depending on the facts
Both SOX and Dodd-Frank anti-retaliation protections can apply concurrently; courts analyze each statute's coverage independently.
Question 7: What is the primary purpose of a 'speak-up' culture survey administered alongside a hotline program?
- Identify individual reporters for recognition
- Benchmark hotline call volume against industry peers
- Assess employee willingness to report and perceived safety (Correct answer)
- Determine the compensation structure for the compliance team
Correct answer: Assess employee willingness to report and perceived safety
Speak-up culture surveys measure employees' comfort with reporting misconduct and confidence that they won't face retaliation, informing program improvements.
CCB Whistleblower & Hotline Management 2
Under the Dodd-Frank Act, what is the minimum percentage of sanctions a whistleblower must qualify for to receive an award from the SEC?