Comment Text:
RIN 3038-AE50
the proposed changes to the rules are all attempts to make the process easier to understand, as in the current form is too difficult and lengthy to be able to understand the correct procedure, and could likely deter a whistleblower due to the difficulty of the current process, especialy f the wistleblower has to surrender his own due rewards for the cause.
care should be taken when deciding o the ability to give the award to other people other than the original source, as certain groups should be excluded, as the positions they possess, and the amounts associated with the awards I feel could become an ethical deterrant. ie: lawyers individually I think should be excluded, as the bounty is easy to be deterred by a lawyer who would be in the position to be able to have the forsight towards a claim, and use confidentiality as an excuse to deny the potential whistle blower of intended rewards. if it is a joint application then the lawyer should be included, but otherwise the possibility of unethical actions would be a deterrant especially if the bounty is large. the implcations would also effect the length of the case, and could effect the integrity of the programme if it was ever discovered.
if the original information source was subject of investigation, and the potential wistleblower alerted authorities in a timely manner then situations like that should be allowed-bear in mind the personal circumstances of the victim, as the confidentiality requirement could pose a problem especially if the legal representation had an alternative motivation, as the legal representation could leave the whistle blower very doubtful of process, and unsure of authority if the legal representation was caught misleading the client.
the ability to give the award and changing the protocol, to allow the whistleblower to receive related actions is a good incentive, especialy if the whistleblower (which would be common) is inexperienced in the protocol and had made simple mistakes.
it can be very difficult and frustrating the whole procedure, and asking the whisteblower who may have ad an interest in the case is a big ask especially when the client/victim has been lied to throughout the whole procedure and by people who were meant to have moral obligations.
the changes in process is an efficient change to the programme, that would make it more efficient, and allow the general public who would lack the knowledge to the exact process, and limited by the costs of lawyers to participate in this programme, but care is still needed when assessing the situation.
THE COLLATERAL would be surrendered if it assists in the progression of this programme, as a vehicle to promote a transparent marketplace, guidance is needed though for the layman to understand protocol.
