What’s Going On – Over a Month of Section 219 Disclosures Under the Iran Threat Reduction and Syria Human Rights Act of 2012

March 20, 2013

What’s Going On – Over a Month of Section 219 Disclosures Under the Iran Threat Reduction and Syria Human Rights Act of 2012

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Section 219 (codified as Section 13(r) of the Securities Exchange Act) has been in effect for six weeks. During this time, more than 100 SEC-registered reporting issuers have made required disclosures regarding their Iran or SDN-related activity. Collectively, these disclosures highlight several issues confronting this new reporting requirement. More importantly, these disclosures make it clear that further guidance regarding the Section 219’s disclosure procedure would be most beneficial.

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