Property Disclosure Rules for Mining Registrants: SEC’s Proposal Would Align Its Disclosure Requirements With Current Industry and Global Regulatory Standards

Sullivan & Cromwell LLP - July 6, 2016

The SEC has proposed rules to modernize property disclosure requirements for mining registrants under a new subpart 1300 of Regulation S-K that would replace requirements currently set forth in Item 102 of Regulation S-K, Item 4.D of Form 20-F and Industry Guide 7. The proposed rules represent a significant overhaul of the existing requirements, and would bring the  SEC’s rules in line with current industry and global regulatory practices and standards, providing more comprehensive disclosure on a registrant’s mining properties.  The proposed rules would apply to U.S. reporting companies and non-U.S. companies reporting on Form 20-F.