[C]laimant 1's award application presents no negative award factors, as Claimant 1 was not culpable, did not unreasonably delay in reporting the wrongdoing, and did not interfere with any internal compliance or reporting system. In addition, the presumption of a maximum award should not be departed from because Claimant 1 provided substantial assistance and the maximum award would not be inconsistent with the public interest, protection of investors, or the objectives of the whistleblower program. 

In determining that Claimant 1 should receive an award of 28% of any monetary sanctions collected or to be collected in the Covered Action, we considered that Claimant 1 alerted government authorities to the underlying misconduct first, resulting in the opening of the investigation; Claimant 1 provided significant new information that made a substantial and important contribution to the success of the Covered Action; and Claimant 1 provided substantial and continuing assistance during the investigation and litigation that helped stop a fraudulent scheme preying on investors. In determining that Claimant 2 should receive a smaller award percentage, we considered that Claimant 2 provided the information after a period of delay, that much of the information Claimant 2 provided was already known to the Commission because of information previously provided by Claimant 1, and Claimant 2's new, helpful information was limited in nature.