2012 SEC comment letter trends: Energy industry

December 2012
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2012 SEC comment letter trends: Energy industry

At a glance

This publication provides an analysis of SEC comment letters issued to registrants across the energy value chain, including exploration and production, midstream, downstream, drillers, oilfield services, and integrated energy companies.

The energy industry has proven to be dynamic and agile: adapting to new challenges, adopting new rules and regulations and pursuing opportunities in an increasingly global economy. In 2012, the energy industry faced many changes including continued volatility of oil prices and gas prices reaching record lows, increased regulatory scrutiny of hydraulic fracturing operations and the adoption of new accounting rules focused on goodwill, comprehensive income and fair value measurements.

For the energy industry, the SEC has not only focused on general areas common to all industries, but also honed in on energy industry specific accounting and disclosure matters. As the energy industry is comprised of various subsectors—upstream, downstream, midstream and oil and gas field services—variations in comments received by the subsectors also exist.

Given the diversity of factors impacting registrants in the energy industry, transparent and robust disclosures in financial reporting continue to be of extreme importance.