A claim alleging whistleblower retaliation under the Dodd-Frank Act was held to be subject to an arbitration agreement, thwarting an employee’s attempt to bring his claim in court. Khazin v. TD Ameritrade Holding Corp., 773 F.3d 488 (3d Cir. 2014) (No. 14-1689). The employee argued that an anti-arbitration provision in the Sarbanes-Oxley Act, which provides a cause of action for whistleblowers, bars mandatory arbitration for whistleblower claims brought under the Dodd-Frank Act. The court disagreed, observing that the two acts are substantively different and each has its own prohibited conduct, statute of limitations and remedies. In view of the differences between the two statutes, and the absence of an express anti-arbitration provision in Dodd-Franks, the court concluded that the anti-arbitration provision in SOX does not bar enforcement of arbitration agreements as to Dodd-Frank claims.