Timothy O'Toole was quoted regarding the ongoing federal tax dispute between Vanguard and one of its former lawyers, which underscores the likelihood that provisions under the Dodd-Frank Act may encourage in-house attorneys to become corporate whistleblowers. The rules that the Securities and Exchange Commission (SEC) has written to implement Dodd-Frank's protections and rewards for corporate whistleblowers have created an incentive for attorneys to test the limits of state codes of conduct, and tension between corporate lawyers and their clients has risen as a result, O'Toole said. This tension is a result of the ambiguity in SEC rules as to the circumstances under which an attorney is permitted to breach his or her promise of confidentiality.