UPDATE: Final rules delayed until at least August 2011

A sleeper provision in the 2,200 page Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act” or the “Act”) requires SEC-regulated oil, natural gas, and mining companies to disclose information related to payments made to foreign governments or the United States government in connection with activities that run the gamut from exploration and development to extraction, processing, and export.

Specifically, Section 1504 applies to “resource extraction issuers” that file Form 10-K, 20-F, or 40-F annual reports (“Issuers”), requiring them to disclose, in those annual reports and electronically, certain information regarding payments to either the U.S. government or a foreign government for the purpose of the commercial development of oil, gas, or minerals.

Please see full Alert below for further information.