This article, by Squire Sanders partner Rebekah J. Poston and associate Carine M. Williams, notes that the Dodd-Frank Wall Street Reform and Consumer Protection Act contains a number of provisions affecting the natural resource extraction industry. Included are new annual reporting requirements, and disclosures on the type and amount of payments to government entities. Difficulty arises with the lack of specificity in some of the definitions, such as that for “issuers,” as well as the lack of definitions for oil, natural gas or minerals. Though transparency in the industry could be a good thing, the article concludes that clear, comprehensive rules are required.
Reprinted with permission from Complinet Group Ltd., a Thomson Reuters business.