On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) issued final rules on Section 1504 of the Dodd-Frank Act, which requires resource extraction issuers to publicly disclose certain payments made to the U.S. and to foreign governments that are more than $100,000 in a fiscal year. Payments must be detailed by type and total amount and must be reported on a project-by-project basis. Intended to bring greater transparency and accountability to the industry, these new rules are controversial and have raised concerns about the added cost of compliance and whether there are competitive disadvantages to issuers. Companies with reporting requirements under this new rule should begin as soon as possible to determine how and whether these new rules apply.
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