Earlier this year, the New York Department of Financial Services (“DFS”) issued guidance on whistleblowing programs. The guidance broadly defines “whistleblowing” and applies to privately held, state-chartered non-depository institutions licensed in New York, in addition to all other DFS-chartered, licensed and regulated institutions. For a number of reasons, the guidance merits review.
Our monthly breakfast briefing will highlight the principles the DFS believes should be accounted for when designing and implementing a whistleblowing program. The discussion will include:
- A summary of the DFS guidance and the entities covered by it;
- A comparison to similar federal guidance; and
- A dialogue about considerations for designing and implementing a whistleblower program.