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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.
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