In Berman v. NEO@OGILVY LLC, the Second Circuit held that a whistleblower does not have to report to the SEC to be afforded the anti-retaliation protections of the Dodd-Frank Act. The court discussed that legislative history was scant, as conflicting provisions were added by the conference committee without explanation. As a result, the court found the statute was sufficiently ambiguous to warrant deference to the SEC interpretation under the Chevron analysis.