Eight Law Firm Report: Exchange Act Section
13(r) Disclosure Guidance

The provisions of the Iran Threat Reduction and Syria Human Rights Act of 2012 require public companies to disclose information pertaining to certain Iran-related activities and transactions in periodic reports (Forms 10-K, 10-Q, 20-F and 40-F) required to be filed with the SEC after February 6, 2013. Although the staff of the SEC’s Division of Corporation Finance has issued interpretative guidance on the disclosure requirements, additional questions remain. We joined a group of law firms in issuing a report that includes guidance on certain other key questions about the disclosure requirements. A copy of the consensus report is available here.