On May 8, 2014, the United States District Court for Southern District of New York found that a former public company employee may proceed with her retaliation claims stemming from her dismissal after complaining of faulty risk-control practices at her former employer.  Yang v. Navigators Group Inc.,13-2073 (S.D.N.Y. May 8, 2014).  The defendant sought judgment on the pleadings on plaintiff’s claims under Dodd-Frank’s anti-retaliation provisions under the theory that plaintiff failed to raise her concerns to the SEC.  Rather, plaintiff , the former chief risk officer, only raised her concerns about her company’s risk management practices, which she alleged violated the federal securities laws, internally at the company.  In rejecting the defendant’s argument, the court stated that Dodd-Frank “does not clearly and unambiguously limit whistleblower protection to individuals who report violations to the SEC.” In reaching its decision, the court noted the ambiguity in the statute and stated that the SEC's interpretation, as expressed in its whistle-blower regulations, “is a reasonable reading of the statute that resolves the ambiguity.”  In reaching this conclusion, the court declined to follow the Fifth Circuit’s decision in Asadi v. G.E. Energy (USA), L.L.C., 720 F.3d 620 (5th Cir. 2013), which found the Dodd-Frank anti-retaliation provisions to be unambiguous and refused to give deference to the SEC’s rules implementing the anti-whistleblower provisions of Dodd-Frank.