The SEC has adopted final rules under the Securities Exchange Act of 1934 to require issuers engaged in the commercial development of oil, natural gas or minerals to disclose information on an annual basis relating to any payment made during the fiscal year to a foreign government or the U.S. federal government for the purpose of the commercial development of oil, natural gas or minerals. The final rules, which were adopted by a vote of 3 to 2 (Commissioners Lee and Crenshaw dissenting), are substantially similar to the rules proposed in December 2019. Our Memorandum to Clients, published on January 15, 2020, summarized key aspects of the proposed rules.