I am writing in regards to the notice that the Securities and Exchange Commission (SEC or the Commission) will, on Wednesday, December 16, 2020, consider adopting rules that “will require resource extraction issuers to disclose payments made to the U.S. federal government or foreign governments for the commercial development of oil, natural gas, or minerals.” [1] While these rules are mandated by Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), [2] which requires “that all oil, gas, and mineral companies on the

U.S. stock exchange disclose any payments they make to foreign governments for licenses or permits for development,” [3] the SEC’s proposal fails to combat corruption and hold bad actors accountable. Instead, the SEC’s proposal “would make such disclosures so general as to be of little value.” [4] Rather than rushing to push through a grievously flawed final rule in the final few days of the Trump administration and your tenure as SEC chair, the Commission should not hold a vote on the rule until these concerns are addressed.

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