RCMS RCMS Whistleblower Programs & Reporting Obligations 2 — Questions and Answers
Question 1: Under Dodd-Frank, the SEC's anti-retaliation protections for whistleblowers apply to which category of reporters?
- Individuals who provide information to the SEC about potential securities law violations (Correct answer)
- Only employees of registered broker-dealers
- Any person who reports concerns to their internal HR department
- Employees who file grievances under collective bargaining agreements
Correct answer: Individuals who provide information to the SEC about potential securities law violations
Dodd-Frank's anti-retaliation protections apply to individuals who provide information to the SEC about possible securities law violations, regardless of employment status.
Question 2: A compliance manager receives an anonymous hotline report alleging procurement fraud. What is the appropriate first step?
- Assess the credibility and specificity of the report before initiating a full investigation (Correct answer)
- Immediately notify law enforcement
- Disclose the allegation to all employees
- Archive the report without action if no prior similar reports exist
Correct answer: Assess the credibility and specificity of the report before initiating a full investigation
The first step is to triage the report by assessing its credibility and specificity to determine whether a formal investigation is warranted.
Question 3: Which law protects employees who report violations of environmental, nuclear safety, or transportation regulations from retaliation?
- Various sector-specific whistleblower statutes enforced by OSHA (Correct answer)
- Only the False Claims Act
- Exclusively Dodd-Frank provisions
- The National Whistleblower Center Act
Correct answer: Various sector-specific whistleblower statutes enforced by OSHA
OSHA administers over 20 sector-specific whistleblower protection statutes covering industries such as transportation, environment, nuclear, and food safety.
Question 4: What is 'retaliation' in the context of whistleblower compliance?
- Any adverse employment action taken because an employee engaged in protected activity (Correct answer)
- Terminating an employee for poor performance unrelated to any report
- Reassigning an employee based on business needs before any report was made
- Issuing a written warning for a policy violation unconnected to a complaint
Correct answer: Any adverse employment action taken because an employee engaged in protected activity
Retaliation is any adverse employment action — including demotion, harassment, or termination — causally connected to an employee's protected reporting activity.
Question 5: Which best practice ensures a whistleblower hotline remains effective and trustworthy over time?
- Regularly publishing aggregate statistics on reports received and actions taken (Correct answer)
- Requiring all reports to include the reporter's name and department
- Routing all hotline reports exclusively to the CEO
- Limiting hotline access to senior management only
Correct answer: Regularly publishing aggregate statistics on reports received and actions taken
Publishing aggregate statistics demonstrates that reports are acted upon and builds employee trust in the reporting system.
Question 6: Under the IRS whistleblower program, awards are available for information leading to the collection of unpaid taxes exceeding what threshold?
- $2 million in disputed amounts (Correct answer)
- $100,000 in disputed amounts
- $500,000 in disputed amounts
- $10 million in disputed amounts
Correct answer: $2 million in disputed amounts
The IRS mandatory award program applies when the amount in dispute exceeds $2 million, with awards ranging from 15–30% of collected proceeds.
RCMS RCMS Whistleblower Programs & Reporting Obligations 2
Under Dodd-Frank, the SEC's anti-retaliation protections for whistleblowers apply to which category of reporters?