On August 22nd, the SEC adopted new rules implementing the Dodd-Frank Act's provision requiring resource extraction issuers to disclose certain payments made to the U.S. government or foreign governments. The Dodd-Frank Act directed the SEC to issue rules requiring companies engaged in the development of oil, natural gas, or minerals to disclose the payment information annually by filing a new form with the SEC called Form SD. A resource extraction issuer is required to comply with the new rules for fiscal years ending after September 30, 2013. The form must be filed with the SEC no later than 150 days after the end of the firm's fiscal year. SEC Press Release. See also Gallagher Dissent. The Globe and Mail discussed the competitive disadvantage U.S.-listed firms may face as a result of the rule. Disadvantaged. On August 23rd, The Hill noted the questions the rules face before they become effective. Hurdles include legal challenges to the rules' cost-benefit analysis and changes in SEC leadership which may result in different interpretations of the rules. Challenges.