TheCorporateCounsel.net

While I mentioned the looming resource extraction issuer disclosure deadline back in the March, I feel compelled to mention it again because we now find ourselves just a couple months away from when affected issuers will be required to file a Form SD to disclose the payments contemplated by the rule. I feel that because the rule has had such a tortured history, it is somehow sneaking up on us now, with the Form SD deadline being 270 days after the end of the resource extraction issuer’s fiscal year. The SEC has had the notion of revisiting the resource extraction issuer disclosure rule on its Reg Flex Agenda for some time, but now all hope is lost that any changes will be made or a delay in the deadline will be adopted before the September 26, 2024 Form SD filing deadline for calendar year end companies.

If your company falls within the definition of a resource extraction issuer and you have not yet started preparing your Form SD, I encourage you to check out our “Resource Extraction” Practice Area.

– Dave Lynn