On March 1st, the U.S. District Court for the District of Massachusetts addressed whether Section 922 of the Dodd-Frank Act, which makes unenforceable agreements requiring the arbitration of Sarbanes-Oxley Act whistleblower claims, applies to a whistleblower case initiated prior to the signing of the Dodd-Frank Act. The Court held that in the absence of clear legislative intent, and given the procedural, as opposed to substantive, character of the provision, the Court, rather than an arbitrator, has subject matter jurisdiction over the whistleblower claims asserted. Pezza v. Investors Capital Corp.