Haynes and Boone has tracked 105 North American oil and gas producers that have filed for bankruptcy since the beginning of 2015. These bankruptcies, including Chapter 7, Chapter 11, Chapter 15, and Canadian cases, involve approximately $67.9 billion in cumulative secured and unsecured debt. As of October 19, 2016, 61 producers have filed bankruptcy so far this year, representing approximately $50.6 billion in cumulative secured and unsecured debt. Despite the recent spike in oil prices, all indications suggest more producer bankruptcy filings will occur during 2016. The latest Oil Patch Bankruptcy Monitor is available here.
The SEC recently published Compliance and Disclosure Interpretations (“C&DIs“) relating to the CEO pay ratio disclosure rule. This disclosure rule under Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires a public company to disclose the ratio between its CEO’s annual compensation and the median annual compensation of all other employees. The new C&DIs include guidance on the selection of an appropriate alternative compensation measure and clarify that if an alternative compensation measure is utilized to determine the median employee, the time period utilized does not have to be a full annual period. Moreover, the time period utilized does not have to include the date on which the employee population was determined. View our prior post on the SEC’s adoption of the CEO pay ratio disclosure rule?áhere. View the full text of the C&DIs here.
Earlier this month, we provided information regarding the IRS’s release of final Forms 1094 and 1095 and instructions for the 2016 Affordable Care Act (“ACA“) reporting year, which is available here. A more in-depth look at the changes to the ACA’s shared responsibility reporting requirements is available on our new companion blog, HB Health and Welfare. HB Health and Welfare provides more details regarding health and welfare benefits topics of interest, and also provides information about upcoming speaking engagements by Haynes and Boone’s benefits lawyers.