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Dodd-Frank Financial Reform Act Imposes New SEC Reporting Requirements on Publicly Traded Mine Operators

Client Alert | 1 min read | 08.17.10

The financial reform law that Congress passed recently includes comprehensive new reporting requirements for publicly held companies that are also mine operators, or that have subsidiaries that are mine operators. The new law will take effect on or before August 20, 2010.

Section 1503 of the Dodd-Frank Act requires covered companies to report to the Securities and Exchange Commission ("SEC") certain enforcement actions taken by the Mine Safety and Health Administration ("MSHA"), such as significant and substantial ("S&S"), unwarrantable failure and flagrant violations, closure orders for failure to abate or for an imminent danger, and pattern of violation notices and orders. Companies must also disclose, for the period of the report, the total number of fatalities, the total amount of assessed penalties and information about their cases pending before the Federal Mine Safety and Health Review Commission. All of this information must be reported on the SEC's Form 10-Q and Form 10-K on a quarterly basis.  In addition, companies must report on SEC Form 8-K within four business days receipt of any imminent danger order, pattern of violations notice or notice of a proposed pattern.

Penalties for willfully failing to make the required disclosures are far greater than penalties for knowing or willful conduct under the Mine Act, and can be as high as $5,000,000 for individuals or $25,000,000 for companies.

The SEC has not issued regulations or other guidance to help companies understand what they must do to comply with these new requirements, and it is unclear whether or when the SEC will do so.

Insights

Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....