On the recordFebruary 1, 2017
We are all painfully aware that Washington's financial control law, Dodd-Frank, is full of provisions that have nothing to do with protecting consumers or preventing another financial crisis. The SEC rule in question today is no exception. This politically motivated rule, tucked into a provision under the miscellaneous provisions of Dodd-Frank, fails to advance the core mission of the SEC, which is to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. Ensuring that payments by oil, gas, and other mineral companies are transparent and accountable is a worthwhile public policy goal, but it is outside the securities laws' core mission of investor protection. Not only should this rule and its enforcement fall outside the purview of the SEC, but the rule itself is fundamentally flawed. Like so many rules and regulations emanating from Dodd-Frank that harm our economy, it is more complex and costly than is required by statute, which calls into question the extent to which it meets the SEC's economic analysis requirement. The SEC itself estimates the cost for compliance at between $239 million to $700 million initially and from $96 million to $591 million annually after that. I am also concerned that this rule could force companies to withdraw from certain countries. Among other things, some foreign countries have laws to prohibit the sort of disclosures called for in this rule.…





