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Client Alert

Federal Court Vacates the SECs Section 1504 Reporting Requirements for Payments to Governments by Oil, Gas, and Mining Companies

July 08, 2013

BY SAMUEL W. COOPER & S. JOY DOWDLE

In yet another blow to rulemaking efforts by the Securities and Exchange Commission under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Federal District Court in Washington, D.C. vacated the Commission’s Section 1504 reporting rules, which required oil, gas, and mining companies to publicly disclose on Form SD payments to the U.S. and foreign governments. While Dodd-Frank’s reporting mandate remains, impacted issuers have escaped the immediate reporting deadlines, and instead must await further rulemaking by the Commission.

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