The SEC continues to question oil and gas companies’ disclosures about the risks involved with hydraulic fracturing.4 Most recently, the SEC’s comments have focused on what it perceives as potential operational and financial risks, such as possible underground migration or surface spillage. The SEC has also continued to seek additional disclosure regarding insurance coverage for accidents and environmental liabilities associated with hydraulic fracturing. In responding to the SEC comments, issuers tend to assert that they are not subject to material risks with respect to their hydraulic fracturing activities, but, nonetheless, agree to enhance disclosures in later filings.