The staff of the Securities and Exchange Commission’s Division of Corporation Finance, in connection with its review of periodic reports filed by exploration and production (E&P) companies in 2015, has recently issued a number of comment letters to these companies asking them to quantify the impact of low commodity prices on their proved reserves and results of operations. During periods of low commodity prices in the past, reporting E&P companies have typically included in their risk factor and MD&A disclosures general statements regarding the effects these low prices could have on their businesses.

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