SEC Provides Much-Needed Guidance on Resource Extraction Payments Disclosure

On May 30, 2013, following numerous requests from the public, the U.S. Securities and Exchange Commission (SEC) issued answers to several questions regarding the disclosure of payments by resource extraction issuers (the Guidance). The Guidance provides much-needed clarifications regarding several aspects of the scope and applicability of the rules regarding resource extraction payments under the Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act). While the Guidance does not answer all questions issuers will have under the new requirements, they are a helpful start from the SEC. Issuers should bear this Guidance in mind when designing and implementing policies, controls, and procedures for identifying, tracking, and reporting covered resource extraction payments in anticipation of their filing requirements.