ETHICAL AND COMPLIANCE CONSIDERATIONS ASSOCIATED WITH THE RECENTLY REVISED RESERVES DISCLOSURE RULES AND RELATED CORPORATE DECISION MAKING

摘要

On the last day of 2008, the U.S. Securities and Exchange Commission (SEC) adopted amended rules for public exploration and production (E&P) companies' disclosures of their oil and natural gas reserves and other oil and gas data. While the amended rules were not effective until January 1, 2010, they quickly generated numerous questions about how they should be interpreted. This chapter summarizes how companies have responded to these amended rules' requirements and how comments from the SEC staff can impact companies' corporate compliance practices. Issues raised by the amended rules also draw attention to the ethical concerns for attorneys involved in their clients' reserves reporting compliance. Many of these concerns are relevant for private as well as publicly held company clients. This chapter will also explore and highlight other ethical and compliance pitfalls for attorneys advising their corporate clients.