On September 10, 2015, the Second Circuit in Berman v. Neo@Ogilvy LLC, 2015 U.S. App. LEXIS 16071 (2d Cir. 2015), ruled that whistleblowers need not report to the U.S. Securities and Exchange Commission (SEC) in order to state a claim for unlawful retaliation under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) anti-retaliation provisions. The split with the Fifth Circuit’s contrary decision in Asadi v. G.E. Energy (USA), LLC, 720 F.3d 620 (5th Cir. 2013), sets up a potential review by the U.S. Supreme Court. See September 14, 2015, Legal News: Whistleblower Developments.