SEC Proposes Revised Rules to Implement “Resource Payments” Disclosure Requirements of the Dodd-Frank Act: Proposed Rules Seek to Address Issuers’ Concerns About Cost of Compliance and Potential Competitive Harm

Sullivan & Cromwell LLP - January 15, 2020

The SEC has re-proposed rules under the Securities Exchange Act of 1934 that would require an issuer who engages 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 proposed rules, released in December 2019, are mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Comments are due no later than March 16, 2020.