The United States District Court for the Eastern District of Wisconsin refused to allow a plaintiff to amend his complaint where the plaintiff claimed he was terminated because he complained internally and to the FTC and the FDIC about the defendants’ regulatory violations. The plaintiff sought to file an amended complaint where he sought to add a claim for violation of the whistleblower-protections of the Dodd-Frank Act.

The court did not allow the plaintiff to amend the complaint because the Dodd-Frank anti-retaliation protections only apply to disclosures related to violations of “securities laws.” The court said the “banking laws” the defendants were alleged to have violated were not “securities laws.”