On December 11, 2015, the U.S. Securities and Exchange Commission (the “SEC,” or the “Commission”) issued re-proposed rules (the “Proposed Rules”), as authorized under Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). Enacted in 2010, Section 1504 instructed the Commission to adopt rules requiring every SEC-registered public oil, natural gas and mining company to submit an annual report disclosing information about payments they made to the U.S. federal government or any foreign government for the purpose of developing hydrocarbons or minerals.

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