It has been over eight months since SEC-registered issuers began making mandatory disclosures of business activities in or with Iran. During that period, issuers have filed over 400 Iran Notices with the SEC, including numerous repeat filers. Being two full reporting periods removed from enactment of this landmark reporting requirement, it seems that the time is now ripe to assess how SEC-registered issuers are adjusting to their new reporting obligations.

Noteworthy Trends -

- The collective disclosures reveal a general disclosure format.

- Reporting issuers continue to recognize that the SEC interprets both “affiliate” and “control” broadly.

- Private equity firms and sponsors are triggering intricate and overlapping reporting trees.

- Reporting issuers are revamping their internal controls to accommodate their new reporting obligations.

- Reporting issuers continue to make disclosures of de minimis conduct.

- Some issuers are reading Section 219 as having a duty to update.

- Disclosures vary drastically in scope and detail across industries.

- To date, the government has not announced the results of any of the mandatory investigations triggered by Section 219 disclosures.