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Even so, the Act defines whistleblower as any individual who provides, or 2 or more individuals acting jointly who provide, information relating to a violation of the securities laws to the Commission…" Indeed, the Act even provides an exhaustive list of those precluded from collecting an award, and hedge funds and/or short-sellers are not included on the list, provided, of course, that the whistleblower provides original information." Therefore, while a literal interpretation of paragraph 922 does not preclude a hedge fund or short-seller from collecting a whistleblower award, it does appear that they have a few hurdles to get over.
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Since the language contained in Dodd-Frank is the same as the language contained in the FCA, the result certainly does not bode well for a short-seller or hedge fund hoping to collect a reward under paragraph 922. But, importantly, Dodd-Frank contains a caveat to the original information" language contained in the FCA. Under Dodd-Frank, unlike the FCA, original information" includes not only independent knowledge, but also adds the word analysis". Accordingly, it seems plausible that an analysis, such as that performed by Brickman & Greenlight, might pass muster even though the information on which the analysis was based is obtained entirely from information that is publicly disclosed. Although using different terminology, that was essentially the crux of Brickman & Greenlight's argument over allegation or transaction" — that they were the first parties to compile the publicly available information and relate it to fraudulent transactions.