Complying with the 2008 Amendments to the Oil & Gas Disclosure Rules: The First Wave of SEC Comment Letters | Practical Law
This Article discusses compliance with the 2008 amendments to the oil and gas disclosure rules for public companies. It provides a summary of two significant reserves-related disclosure rules introduced by the amendments: a five-year rule for proved undeveloped reserves (PUDs) and a rule permitting companies to prove their reserves through reliable technology. By examining SEC comment letters in response to the first wave of Form 10-K filings under these new rules, this Article provides valuable insight into the SEC's main areas of focus under the amended disclosure regime.