Section 1504: A Burden For Resource Extraction Cos.

Law360, New York (September 7, 2012, 4:10 PM EDT) -- On Aug. 22, 2012, the U.S. Securities and Exchange Commission adopted, by a 2-1 vote, the final rule implementing Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. This rule requires certain oil, natural gas and mineral companies to disclose annual payments made to U.S. or foreign governments in an effort to increase the transparency of such expenditures and thereby improve government accountability in resource-rich countries.

The implications of this rule are significant: Section 1504 will likely impose substantial compliance costs on the firms implicated by the rule and create potential Securities Exchange Act liability for these issuers....

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