Recent trends in SEC comments issued to oil and gas companies, and an enforcement action against one such company, illustrate current SEC priorities relating to the industry.
We are now at the point in the calendar-year reporting cycle when comments of the SEC staff on annual reports for the prior year, and the current year’s proxy statements, have generally become publicly available. Issuers in the energy industry may want to consider the content of frequently-issued comments specific to energy issues as they prepare for the upcoming annual reporting cycle, as those comments provide an indication of relevant SEC staff concerns. Also potentially relevant is the outcome of a recent SEC enforcement action against a publicly-traded E&P company, and a related federal appeals court decision, arising out of alleged deficiencies in its disclosures.
As discussed in our client alert of June 24, 2014, the U.S. Supreme Court in Utility Air Regulatory Group v. EPA (UARG) invalidated EPA’s greenhouse-gas (GHG) regulations to the extent those regulations required stationary sources to obtain Prevention of Significant Deterioration (PSD) and/or Title V major source permits based solely on the source’s GHG emissions (termed "non-anyway" sources). On July 24, 2014, EPA issued a memorandum to the regional administrators outlining several next steps following the UARG decision.
Greg L. Gambill has joined the Health Care Group of Davis Graham & Stubbs LLP as an associate. Mr. Gambill's practice is oriented to regulatory, litigation, and transactional matters affecting clients in the health care industry. He has presented to attorneys and health care organizations about health law and commercial law.
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