This week on the Business Integrity School Podcast, host Cindy Moehring is talking with Jane Norberg. Jane is an accomplished lawyer who is now partner at Arnold and Porter, before this she was Chief of the Office of the whistleblower at the Securities and Exchange Commission. Cindy and Jane talk about all things whistleblower law and how to come forward while utilizing your resources. Listen in to hear all about whistleblower law!  

Learn more about the Business Integrity Leadership Initiative by visiting our website at https://walton.uark.edu/business-integrity/ 

Link from the episode: 

SEC Whistleblower Office Announces Results for FY 2022: https://www.sec.gov/files/2022_ow_ar.pdf   

Crisis of Conscience—Whistleblowing in an Age of Fraud by Tom Mueller: https://a.co/d/fy2CxWp  

Hi, everyone. I'm Cindy Moehring, the founder and Executive Chair of the business integrity Leadership Initiative at the Walton College of Business, and this is the business integrity school podcast. Here we talk about applying ethics, integrity and courageous leadership in business, and most importantly, in your life today. I've had nearly 30 years of real world experience as a senior executive. So if you're looking for practical tips from a business pro who's been there, then this is the podcast for you. Welcome. Let's get started. Hi, everybody, and welcome back to another episode of the business integrity school. We have a very special guest with us today. Jane Norberg Hi, Jane. Hello,

thanks for having me.

Absolutely. Let me tell you guys a little bit about Jane and what an honor it is to have her with us today. And then we'll jump right into the questions. Jane is now a partner at Arnold and Porter, where she represents public and private companies, financial institutions, individuals and investment advisors on sensitive whistleblower and other complex matters. And the reason she is so qualified to do that is prior to joining Arnold and Porter, Jane was the Chief of the Office of the whistleblower at the Securities and Exchange Commission. Jane joined that office just shortly after its inception in like 2012, as Deputy Chief four years later, she became the chief. And she really helped develop that entire office and lead the program. Like I said, nearly since its inception, she also has extensive experience and knowledge regarding whistleblower retaliation, which we'll get into a bit in this video podcast. She's also a former special officer in the Division of Enforcement at the SEC, and interestingly, also a former Special Agent with the United States Secret Service. So Jane, wow, it is a true honor to have you here today. Thanks for spending some time with us.

Thank you. Thank you for having me on. I'm happy to do it.

Well, I have to ask you first, how did you find your way from? Like being a special agent with the Secret Service to the office of the whistleblower at the SEC?

Yeah, it's funny, whenever anyone asked me that question, I always joke. It's like the long and winding road. When you're thinking about a career path, it isn't always linear. And it isn't always what you thought it was going to be when you started out. And so I was a special agent with the Secret Service. And that was really right out of college. And so I was with them. And I went to law school at night, during part of my stint as a as a secret service agent. And so I was not only law school, law school by night, I was also, you know, arresting people who were bringing in counterfeit money through JFK Airport, as well during the day. So it was it was quite a quite an experience, maybe not your average law school experience, I know. But from from there, I did go to work at a larger law firm in New York City, where I practice of all things, which sounds like nothing like what I'm doing now. But it was executive compensation and benefits and so dealt a lot with at that time, there's a big boom in IPOs, and mergers and acquisitions, and helping with the stock options and incentives for executives and employees and making sure everything mashed underneath the for the companies and underneath the law. And so that brings me to the SEC, because I had to deal a lot with the Securities Exchange Act of 1934. And so I always had a real interest in disclosures and how those disclosures could potentially impact investors. But I lived in New York City. And so the thought of working at the SEC never really crossed my mind. Sure. But um, some personal events led us down to the DC area. And so when I arrived here, I wasn't sure what I wanted to do next. And I had young children. And I wasn't sure exactly, you know, where you know what I was going to do next. And then an old colleague told me about this new office, the Office of the whistleblower, that was opening at the SEC, and that they were, you know, seeking a deputy chief. And I knew I always wanted to work at the SEC. And I thought, well, that sounds interesting, because it's a new office. Yeah. And so I, you know, put in my resume, threw my hat in the ring, and was lucky enough to be to be selected for that position, which has totally changed my whole career trajectory.

Oh, yeah. And I love the fact that you described it as sort of this. It's not always linear, it can be a bit of a winding path. And I always encourage students to think about their careers that way, because you know, you just never know. So that's great. So uh, right, you ended up at the SEC whistleblowers office, it was brand new. You're the deputy chief, how did that office even come into being? What's its main purpose?

Yeah, so it It was established pursuant to the dot the Dodd Frank Act. And you all may recall, or maybe you're too young to recall. But it was really born out of a out of a financial crisis in 2008. And it was at the same time that that financial crisis was happening. There was also this thing happening with a Ponzi scheme that was being perpetrated by somebody called Bernie Madoff, which I've heard of Yes. And at that time, there was a very famous whistleblower who testified in Congress talking about how he had reported out to the SEC, and other agencies, and that he felt that the SEC had not taken appropriate action with respect to his tip, how, multiple tips, multiple tips, and the issue there was that his information was going to the SEC was going to different regional offices. And it wasn't all contained in one place. And so not only did the Dodd Frank Act, put in place, the Office of the whistleblower, the separate and apart the SEC realized, you know, after sort of kind of taking it on the chin, so to speak, right, or the Bernie Madoff and rightfully so over the Madoff debacle, they realized, gosh, we need to have like a centralized triaging mechanism. And no, they put in place something called the Office of market intelligence. And that office, actually triage is every single tip that comes into the SEC, including whistleblower tips, so that that nothing falls through the cracks. So even if somebody sends a tip to say, the Boston regional office, it's all getting closed down to one office who's looking at every single piece of intelligence that comes into play, to make connections and determine if there's something material happening. So that was a long winded way to say that the Office of the whistleblower came out of the Dodd Frank Act. And the whole purpose is to incentivize information, individuals with information to report it to the to the SEC, if it involves a possible securities law violation. And in return for that what the whistleblower gets is they get confidentiality protection, meaning that the SEC cannot and will not identify a whistleblower outside the commission, unless it's pursuant to, for example, like a discovery request, if the whistleblower, for example, might be a witness for the SEC. And pursuant to the rules of discovery, the the accused has a right to know if the person might have a monetary interest in the outcome of matter. So then that person might have to be identified. But other than that, I mean, it's a rare day when the SEC would have to identify a whistleblower outside of the Commission. The other thing that they get is anti retaliation protections, which I know a little bit more about later. Yeah. Finally, and probably the thing that gets all of the attention grabbing headlines are the monetary awards, so essential to get a monetary award. If the information is so specific, timely and credible, that the Commission brings an enforcement action we're over $1 million in monetary sanctions are ordered, then that individual is assuming they're eligible otherwise eligible, can receive between 10 and 30% of amounts collected in that matter, and it can be quite substantial.

Yeah, that really is the incentive for a number of individuals is the the monetary awards, and it's been pretty eye popping, at least in the last year, which again, we'll talk about in a minute. But let's, let's talk about that, how those incentives have worked in terms of the just a number of tips, like give us a sense of the size of the SEC whistleblower program, how many? How many tips have come in in the 10 years? And you know, how many chips come in? And then let's say in the last year, what what does that look like? Is it increasing or decreasing? I mean, what what is it?

Yeah, it's it's increasing honestly, to numbers that I never thought would have happened when when the program first started running, you know, just to harken back to like when I started and yeah, that's getting off the ground. I mean, we didn't know you know, were we going to get tips? I mean, obviously, we figured we get some we had no idea of the program was going to be successful. And thankfully, you know, the tips did start did start coming in small numbers at first, but it has gone up is increased year after year after year to the point where last fiscal year. When is the last fiscal year I mean, the end of September through the end of September 2021. Right. They the SEC received over 12,000 whistleblower tips which is up from 6900 that they received the year before. So if you think about that almost double in Wow. And yeah, that go true like anomaly. Like, if you look at the chart, if if the students have an opportunity to take a look at the Annual Report to Congress, you will, if you look at that chart, it's quite stark, because you see, like these small changes, and then all of a sudden, just this huge, long line of like, wow, look at that. Look at that. Look at all those in the last fiscal year.

Uh huh. Yes. Well, we'll drop that report in the show notes for sure. And given that the government's fiscal year is the end of September, we may be able to also include the 2022 report in the show notes, we'll see. But, yeah, I mean, so it is really, really been increasing. Well, at least it did in 2021, and seems to have gone up every year. What are the main types of allegations that that come in? And has that changed over time?

Yeah, interestingly, it hasn't. So when whistleblowers submit tips, they are the ones selecting the allegation category. So if you went in it, there will be a question that says, you know, what are you? What is your complaint about, and that would be a number of categories that they can select from. And the top three have remained the same since the beginning of the program, and they are manipulation, complaints about corporate disclosures and financials and offering fraud. This past year was the first time we had full year data on some new and emerging areas of interest. So for example, crypto currencies and crypto coin offerings, which have been a real focus of the SEC recently, Yes, last fiscal year was the first time they had full year data on that. And I think there was 6% of the tips came in under cryptocurrencies versus that just so you have an idea that the highest category of manipulation was like, 25%. Okay. It was it was it sounds much smaller, but it actually wasn't, I think it was maybe the highest highest thing around the cryptocurrencies. Yeah.

Can you give us just a little bit of a flavor, when we say manipulation, or corporate disclosures and financials are offering fraud? Like, what does that mean?

Yeah, so when you're thinking about corporate disclosures, and financials, that's usually, so they're offering documents that are given out to investors, or I shouldn't even say, it doesn't have to be in the offering documents, it can be in a statement in a press release, or be in an annual proxy statement, or 10 days and the types of filings that a public company must do, right, yes, etc. There are certain requirements under the law have what they have to disclose to investors. And the whole point is to make sure investors have the right, accurate and complete information in order to invest in to make that investment decision. Right. Right. Right. So that's what the SEC is very, very focused on is our investors getting this right information? Yeah. And so a lot of times, whistleblower may come in and say, the company said this in their annual report to in there and report to shareholders, when in fact, I know, because I'm an employee of the company that that is not accurate, that in fact, omitted this information. And so so something along those lines, and one thing, that's kind of a hot topic that I'll mention disclosures, to give you an example. So hot topic right now is ESG. Right? You can right? Look anywhere without hearing about environmental, social and governance, right area. And the SEC is very focused on disclosures related to those topics. So so much so that the SEC is reportedly even looking at companies websites, or their corporate sustainability reports. And so every company wants to now say, I'm this, like, you know, great corporate citizen, doing all this great stuff for the planet, and very environmentally friendly, and that's great. But sometimes I think companies might take it just a step too far and not be able to back it up. And that's really what the what the company is, what the SEC is looking at. Those types of disclosures are accurate.

Yeah. And that, you know, that's a real evolving field. There are a number of regulations that are currently in the pipeline that may come into effect shortly, especially on the environmental side, and how far upstream companies are going to have to go to report that. So yeah, I think there's a big scramble on right now to really be able to backup that data. So that's a that's certainly an evolving topic as well as crypto. I think that we'll probably continue to see that. I don't know if it'll ever overtake the top three since it's been that way for the last 10 years. But that'll be interesting to watch. Okay, so let's talk about who who can report in tips to the SCCs. Office of the whistleblower? Is it just people here in the United States? or can people from outside the United States? Also submit tips? How does that all work?

Yeah. Anybody. Anybody can submit a tip. It was written, I think, intentionally broad, because it just going back to the Bernie Madoff whistleblower, yeah, not an employee of the company. He was an outside person who observed something that he thought was in incorrect. And so it was drawn. The, the net was cast quite wide for that particular reason. So you don't have to be an insider or an employee of a company to be a whistleblower, like literally anybody. I receive tips from competitors from ex spouses who were relationship soured. And they're like, You know what, let me tell you what my boyfriend was doing. Yeah. So really, anybody can be a whistleblower. And so it and US versus foreign citizens? Yeah. Anybody, anybody so give you an idea. I mean, the whistleblower program, they've received tips from every single state in the United States, wow, 133 countries worldwide. And again, harkening back to the first days of the program, I never ever thought that we would receive tips from that number of countries. And so it's really a worldwide reach to this program. And it's really important that, you know, companies really think about that, when they're considering their internal whistleblower policies. The one stat, I will tell you, which I always wish I found, like, it just sort of blew my mind, based on last year's Annual Report to Congress. There have been whistleblowers who had been paid, so meaning their information was good information. And the SEC brought a case based on that information in, in, in six continents. So you're literally only missing one continent, where there's an SEC whistleblower being paid. So that's like, incredible when you think about that,

That really, really is, are there are there particular because there's number of questions I want to ask you here. But are there particular countries that stand out as submitting most of the tips from outside the US?

Yeah, so most years, there's like a top five list that I'd say that the those countries have always remained in it, they've just sort of moved around and ranking. Yeah, right. Canada, the UK, China, India, Australia has been up there. So those are huge. In countries, though, every now and then something happens. And there's a surprise, you know, country that all of a sudden, there's like a lot of tips from that particular year. And that's why if there was something that happened with a company, that that may have had operations based there, potentially, but like, usually those are the top five countries from outside the US.

Okay, so these individuals who have been would be reporting on the operations of, of companies that, by and large, are based in the US and have their headquarters here and are subject to the securities laws. So they're their public companies traded on the exchange, is that the right way to think about it?

That's largely the right way to think about it, though. The SEC has jurisdiction for anyone who trades even ADR. So like American Depositary Receipts can be traded on a US market. So meaning there may be traded on exchange, but they they sell something called ADRs to American investors. And so once that happens, once there's a US investor that can invest their money in that company, right, that is a hook for the SEC,

that's a hook. So it is very, very broad. Okay, so So and I also saw in that report to Congress, that 20% of the awards were were actually made to people, you know, outside the US, and it seems like those numbers continue to rise too. So why, why is that? Do other countries not have a similar program to what the SEC has? Yeah, it's

a really good question. So I think there's, there's a couple of things I would say about that. The US the SEC us program is really unique in that it has those three main components that I spoke about the confidentiality, the anti retaliation and the monetary awards. Got it. A lot of programs you see will have confidentiality. anti retaliation, but there's no monetary award attached to it. And so the monetary award, you know whether people think it's a good thing or a bad thing, right, because I think people can be split on that. Some people might not like this, somebody reports because of the money. But the fact is, is that the monetary monetary award, I think, is a factor in deciding to report. And so I think people may report to their regulator in their particular country, but they're also reporting it out to the US regulator.

Oh, okay. So does the SEC whistleblower office, if it's an international whistleblower? Do they coordinate it all? With the offices in the other in the other jurisdictions or not so much? Or is that maybe on the back end?

Yeah, no, at times, yes. And there's, you know, laws in certain jurisdictions about speaking to citizens in those countries. And so there's a lot of things that have to be navigated. And so the SEC does have an Office of International Affairs that that we spoke to quite often, I bet,

yeah. To

navigate those issues.

Yeah. Okay. So I think what may be on a lot of people's minds right now is just a question of WoW, didn't even didn't know this was available. So when should someone think about potentially using the SEC whistleblower office?

So there's really anytime there's out, you know, possible securities law violation, if you're working at a company, and you see an issue that could be impacting investors, that is when the SEC is interested to receive the information. That said, that said, I think a lot of companies has have some really strong internal reporting structures. Yeah. And I always think it's a good thing to work within a company's internal reporting structures, if you can. Not every company has, is strong in that there, you know, and the SEC did choose to empower an individual to determine whether or not they're comfortable reporting internally or reporting out to the SEC. So internal reporting is not required. Okay. And so what that did right is put it on the employers to put it on, it needs to say you need to bolster your internal reporting structures, yeah, get people comfortable that if they report that they're not going to be retaliated against, or some adverse action isn't going to be taken against them, because I will tell you, when I was the Chief of the Office of the whistleblower, I saw things happen at companies to someone who report it that just blew up the entire relationship, the entire like employment relationship with this individual. Right? When I think it didn't have to be it was just the immediate sort of fear that someone's reporting something and then holding that person at arm's length and viewing them as the enemy, instead of somebody who was, you know, a valued employee who saw something who wanted to bring into the company's attention. And I do see a lot of missteps in that area I saw when I was at the SEC, and I see if you're in private practice, that first touchpoint with an individual is so critical, but in thinking about your students, and you know, them going out into the world and being being leaders and potentially being put in a situation where they're trying to figure out, you know, how to handle something. I mean, it's, it's difficult to be put in that situation. You know, unless you're the, you know, the CEO of a company or the chairman of the board, right? You're always reporting up to somebody. Right? So to me, it's about kind of, like speaking, speaking truth to power, right? So if you see something instead of saying, you know, yes, and just going along with it when you know, it's unethical, or worst illegal, right, probably the worst thing you can do, to me, like taking it and saying, you know, what, here's why this is not correct or accurate. Especially when it's crossing over the line to harming investors and being illegal. It's hard to be in that position. I mean, I've spoken to 1000s of whistleblowers, and every single one of them would say, I don't want this, but it fell in my lap. And so I've got to deal with it. And so it's, it's a difficult situation. And so I think just, you know, being brave enough to recognize it, and to know, okay, you know, what, I can sit here and be complicit in it, and then raising it internally. And then if that doesn't work, raising it outside. Yeah. And I'm sure like a lot of the future the students, the leaders in these companies, I mean, some of them may be in a position, quite honestly, where someone's reporting to them right up there the future, you know, general counsel's or chief compliance officers or CEOs of companies and now That's an even harder position to be in because you have employees reporting up to you. And they're looking at you saying, Okay, now what are you going to do about this? Right? That's right. And, you know, save you from the role you played? It's hard to be in that position. Right and have have that, that on you so hard for the person reporting, and it's hard for the the, the the leader who's taking the report in to know the math. You do.

Yeah. Well, it it is a hard position. And it's interesting, and you encourage people to report internally, and and that report to Congress from the SEC whistleblower office says that most of the award winners from the SEC office actually did try to use the internal channels first, like at least over half, like 60%. And And of that, you know, 75% of them, I think, raise their concerns internally. So over 60% of the award recipients were current or former insider, sorry, got that wrong. So they were current or former employees, and somebody of that group 75% of them had tried to raise the issue internally first. So does that just say to you that it isn't like Why Why was there a need then still to go external to that extent? You know, that those are pretty high numbers? Do you think it's companies don't have the good programs or not doing effective investigations? Or is it just kind of a range of different issues?

I think it's a range of different issues. I think it's an incredibly high number. Yeah. And 75% is actually down a little bit. So the year before that, it was like 84%. So when you think about those numbers, though, that is a phenomenal amount of people who've reported internally. And what that means in my in my eyes is that in 75% of the cases, someone at a company knew that there was an issue, right, knew there was an issue. And they may have taken action, and they had done an internal investigation, but the person still chose to report out, right? Because the truth is, there is still a monetary reward component to the SATs program, yeah, must report it to the SEC in order to avail yourself with a monetary award. So a lot of times, I would see employees reporting internally, and at the same time reporting to the SEC, so you're kind of checking both boxes. So it doesn't mean that they only went one way and then waited to see audit.

I got it. Yeah.

Yeah. But I had heard many times where employees did report internally. And their perception was that there wasn't action being taken or they weren't being taken seriously. It doesn't mean that the company wasn't taking it seriously and wasn't taking steps. It's just that the communication that the company was given to the whistleblower, was lacking or not what that person wanted to hear. Yeah, they felt the need to go outside the company.

Yeah. Okay. So we've we've talked a little bit about the incentives and monetary rewards, let's, let's talk about that, specifically. So what is an average reward that that is given out? And how much has been given out overall, how much is typically given out in a year? Like, like, what kind of money are we talking about here?

So since the beginning of the program, $1.3 billion, has been paid to I think it's around 260. Some individuals at this Wow. So

wait about with a be one point in 10 years? That's a lot of 214 people. That's not that many.

Yeah, yeah. It's a it's a it's a lot and don't quote me on that number. Because it could be wrong with Yeah, but over a billion, it's no, no, it's 1.3 billion is the number of individuals. I'm not. I could have gone up since since my last I'm looking at that stat. But it really is a large number. Last fiscal year, the same year that those that large number of tips increased, the number of awards that went out was was massive. I think it was over half a million dollars in one year. Wow. But that was largely because in that year, there were two very large awards $114 million to like, in one case to one individual. And then the other case, I think, I think there was people who split that 100 and $14 million award. So that's like a massively big, that's a big award to pay. Now, when you ask about the range, what the rules say is that the SEC can only pay on amounts collected. So there is the potential that a whistleblower could get nothing even though their information was good information and successful enforcement action was brought. If it was based on something where the wrongdoer dissipated the funds right there was investor that was lost and they you know, spent it on lavish lifestyles and there's just nothing left. Yeah, even though the SEC was able to stop it stop the fraud from going on. There was just nothing to seize and nothing to grab a hold of right. And so they can end up like between the CIO, the range zero to 100 million is the current range. And so with a lot of in between a lot. So it's really hard to know, you know whether or not you're actually going to get to get an award. I will say, though, that the SEC does do a good job, especially if there's a whistleblower involved in investors that have been harmed of keeping track of wrongdoers, and if they're, you know, getting money from another source or they cease. In one instance, I know they seize, you know, properties and paintings off walls and stuff, in order to auction them off to pay investors back in part and part of that money, then went to the to the whistleblower, well, it didn't reduce what's paid to an investor, I should clarify that there was more awards never reduced what's paid to an investor, there's just a separate funding job. That's put in place, but so So the range is all over the board

all over the board. Okay, so let's talk about retaliation for a minute. Because one of the main reasons people don't report whether it's internally or I would imagine, externally is they just they're worried about retaliation. And I believe that's a separate claim that can be made to the SEC. And in fact, you all have brought, even while you were there some of the first anti retaliation claims. Can you tell us a little bit about how that works?

Yeah, so the under the Dodd Frank Act, the SEC was given the authority, the enforcement power to bring charges against a company for retaliating against a whistleblower, which really gave the in my opinion, the whistleblower program, like really some teeth, right. So, so many, it's the first time that this agency had been allowed to bring a case against a company and charge real fines against a company for retaliating against a whistleblower, not to mention the embarrassment, right of a bigger company that had retaliated, kind of all over the place. Yeah. So there, you mentioned there's been four to date. And that is correct. The reason that there's only been four, when you think about the number of whistleblowers have been paid, it doesn't mean that there's only been four people retaliated against. There was a Supreme Court case, that was brought in by a company called Digital Realty. And in that case, they challenge the SEC has authority to bring retaliation charges against them when the whistleblower did not report the information to the SEC, because he viewed it was, well, they report it internally. And so they're protected, even if they come later. And what the Supreme Court said is no, the information has to be reported to the commission to the SEC, first, before the retaliation takes place. And so that, you know, caused, you know, kind of a ripple effect, right, where you've defined that that right fact pattern where somebody's reporting to the SEC, and then the retaliation took place. As you can imagine, a lot of times what happens, somebody reports internally, there's an adverse employment action that's taken, and then they're like, hold on a second, I'm going to report out. And unfortunately, that that chain of events, that timeline does not work for the SEC to be able to bring an enforcement action. There is still room, you know, statutes that do cover those individuals for retaliation, and usually it's under the Sarbanes Oxley act. So there is a path forward for them. It's just that the SEC cannot bring bring a case against it. Okay.

Okay. Okay. Very good. So this has been really great information. There's just one other area I want to explore with you just a little bit because we've been focused purely on the SEC whistleblower office. But I really think that that office in the past 10 years sort of set a great example for other federal whistle blower programs as well. So do you have a sense of how many different whistleblower programs there are federal whistleblower programs? And what does somebody do if, like, how do they know where to go? And what if they're, like, have a concern with a private company? Is there any recourse there?

Yeah, there's a really good question. So there are a lot of federal programs. More and more, I think, seeing the success of the SEC whistleblower program, have been more federal whistleblower programs that have those three components, the money, the confidentiality, and the anti retaliation protections, right that have been popping up. So I'll give you two main examples. So there's one under the the National Highway Transportation Safety Administration, they have one for whistleblowers who report problems related ,like cars, right? Got it, in fact, okay, defect, things like that that might impact the automotive safety. I know they have paid out whistleblower awards, another new one that just actually came out within the last year or so is under the anti Money Laundering Act. There's a whistleblower program, again, the exact same three components, as the SEC is the community. Commodity Futures Trading Commission also has a mirror, it really is like a sister program to the SEC is because their program was put in place the exact same time as the SEC is, for people who aren't familiar with that the CFTC is a sister organization to the SEC, it's just they have a much smaller jurisdiction. So they don't really grab as many headlines or pay as many awards as an SCP but mostly because our jurisdiction is smaller, but that same type of program. Yeah, and the other one that I can think of that pays a monetary award, the Internal Revenue Service, yeah, yeah, that one is that one is the other one that pays a monetary award. If there's a if they are not a public company, I mean, there's various places that that people can go. There's also state, the state regulators. The one thing I would say is even if there is a, an issue that gets reported to the SEC, and it's something that the SEC can't handle, they do share information, okay, consistent with the confidentiality obligations that they have for whistleblowers, but they do share it with other organizations or law enforcement partners, because if there's something happening, there should be stopped. Got it on. If the SEC has no jurisdiction, they're gonna pass it on.

Got it. Okay. Well, Jane, I want to thank you again, so much for your time. This has been a great conversation. I have a fun question to end on, though. What's the best like book you've read or podcast your documentary you've seen or something that really speaks to this issue? Mainstream media that kind of highlights this issue of speaking up and whistleblowing that piqued your interest?

Yeah, there's a lot of good ones. But the there was a book that was written called crisis of conscience by Tom Mueller. And I have been on a couple of panels together. He's very smart. He's done a lot of research into this topic and spent years honestly talking and interviewing different whistleblowers on different areas. And I thought it was a really compelling a really compelling read. Tom, and I don't necessarily agree on some of the SEC thoughts that he has in there. But other than that, I think it's a you know, I can I have spoken about that. But I think it's a great book I actually think I would recommend. Great.