The U.S. Court of Appeals for the Second Circuit issued a significant opinion last week, reversing a lower court decision and extending the whistleblower anti-retaliation provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd Frank”) to whistleblowers who suffer retaliation as a result of reporting wrongdoing internally, without also reporting to the Securities and Exchange Commission (“SEC”). (Berman v. Neo-Ogilvy LLC, No. 14-4626, 2015 U.S. App. LEXIS 16071 (2d Cir. Sept. 10, 2015)).