<?xml version="1.0" encoding="UTF-8"?><rss version="2.0"
	xmlns:content="http://purl.org/rss/1.0/modules/content/"
	xmlns:dc="http://purl.org/dc/elements/1.1/"
	xmlns:atom="http://www.w3.org/2005/Atom"
	xmlns:sy="http://purl.org/rss/1.0/modules/syndication/"
	xmlns:georss="http://www.georss.org/georss" xmlns:geo="http://www.w3.org/2003/01/geo/wgs84_pos#" xmlns:media="http://search.yahoo.com/mrss/"
		>
<channel>
	<title>Comments on: Accurately Disclosing Oil Reserves</title>
	<atom:link href="http://truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/feed/" rel="self" type="application/rss+xml" />
	<link>http://truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/</link>
	<description>Academic commentary on law, business, economics and more</description>
	<lastBuildDate>Tue, 14 Feb 2012 19:40:24 +0000</lastBuildDate>
	<sy:updatePeriod>hourly</sy:updatePeriod>
	<sy:updateFrequency>1</sy:updateFrequency>
	<generator>http://wordpress.com/</generator>
	<item>
		<title>By: TRUTH ON THE MARKET &#187; More on the SEC&#8217;s Antiquated Disclosures Rules for Oil Reserves</title>
		<link>http://truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5444</link>
		<dc:creator><![CDATA[TRUTH ON THE MARKET &#187; More on the SEC&#8217;s Antiquated Disclosures Rules for Oil Reserves]]></dc:creator>
		<pubDate>Fri, 28 Apr 2006 01:37:57 +0000</pubDate>
		<guid isPermaLink="false">http://www.truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5444</guid>
		<description><![CDATA[[...] Back in February, I criticized the SEC&#8217;s rules regarding how energy companies must disclose their oil reserves in securities filings. My main point was that the conservative manner in which the SEC measures reserves is quite different from the approach the oil companies themselves take when deciding how to invest billions of their own dollars. If the SEC is going to require disclosure of some reserve estimate, shouldn&#8217;t it be the estimate upon which managers are willing to bet the corporation&#8217;s money? [...]]]></description>
		<content:encoded><![CDATA[<p>[...] Back in February, I criticized the SEC&#8217;s rules regarding how energy companies must disclose their oil reserves in securities filings. My main point was that the conservative manner in which the SEC measures reserves is quite different from the approach the oil companies themselves take when deciding how to invest billions of their own dollars. If the SEC is going to require disclosure of some reserve estimate, shouldn&#8217;t it be the estimate upon which managers are willing to bet the corporation&#8217;s money? [...]</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Geoffrey Manne</title>
		<link>http://truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5443</link>
		<dc:creator><![CDATA[Geoffrey Manne]]></dc:creator>
		<pubDate>Thu, 09 Feb 2006 18:46:51 +0000</pubDate>
		<guid isPermaLink="false">http://www.truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5443</guid>
		<description><![CDATA[So the regulators impose a disclosure requirement practically calculated to lead to . . . more regulation.  That does seem surprising.

As Thom notes, one problem with mandatory disclosure of information set x is that it seems to preference information set x over information set y.  There are many market mechanisms to overcome this distortion, but there are few political mechanisms to do so, and even the market mechanisms are imperfect:

For example, even if non-mandatory information would be more valuable to disclose, disclosure always carries with it a lawsuit risk.  At the margin, unless the value of disclosure is greater than the cost, the information won&#039;t be disclosed.  For information subject to mandatory disclosure, this calculation is biased in favor of disclosure.  Not so for the non-mandatory information.  To the extent the mandatory and non-mandatory information sets are substitutes (even imperfect ones), the combination of mandatory disclosure regime and lawsuit risk surely induces some substitution from more-useful to less-useful information.]]></description>
		<content:encoded><![CDATA[<p>So the regulators impose a disclosure requirement practically calculated to lead to . . . more regulation.  That does seem surprising.</p>
<p>As Thom notes, one problem with mandatory disclosure of information set x is that it seems to preference information set x over information set y.  There are many market mechanisms to overcome this distortion, but there are few political mechanisms to do so, and even the market mechanisms are imperfect:</p>
<p>For example, even if non-mandatory information would be more valuable to disclose, disclosure always carries with it a lawsuit risk.  At the margin, unless the value of disclosure is greater than the cost, the information won&#8217;t be disclosed.  For information subject to mandatory disclosure, this calculation is biased in favor of disclosure.  Not so for the non-mandatory information.  To the extent the mandatory and non-mandatory information sets are substitutes (even imperfect ones), the combination of mandatory disclosure regime and lawsuit risk surely induces some substitution from more-useful to less-useful information.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Thom Lambert</title>
		<link>http://truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5442</link>
		<dc:creator><![CDATA[Thom Lambert]]></dc:creator>
		<pubDate>Thu, 09 Feb 2006 14:43:23 +0000</pubDate>
		<guid isPermaLink="false">http://www.truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5442</guid>
		<description><![CDATA[I agree with Bill and Michael that oil companies can, and do, disseminate more accurate reserve information (i.e., the data they themselves rely on) despite the SEC rule.  As Michael notes, they&#039;d likely do so absent any regulatory intervention.

I do think, though, that there&#039;s a real danger in the government mandating disclosure of an affirmatively misleading figure.  There&#039;s a lot of misinformation in the press regarding our purported energy &quot;crisis.&quot;  Pressured by worried constituents, governments are scrambling to invest public money in alternative fuels.  Unlike venture capitalists, who are motivated by profits and will see through faulty metrics, government &quot;investors&quot; are motivated by constituent pressures.  Those pressures are largely influenced by media reports.  Journalists are busy folks and will tend to believe (quite rationally, I suppose) that the information in a mandated securities filing is accurate.  Thus, we end up with all sorts of news stories about how major oil companies are producing at record levels, while their reported reserves are oh-so-small.  Politics takes over from there.]]></description>
		<content:encoded><![CDATA[<p>I agree with Bill and Michael that oil companies can, and do, disseminate more accurate reserve information (i.e., the data they themselves rely on) despite the SEC rule.  As Michael notes, they&#8217;d likely do so absent any regulatory intervention.</p>
<p>I do think, though, that there&#8217;s a real danger in the government mandating disclosure of an affirmatively misleading figure.  There&#8217;s a lot of misinformation in the press regarding our purported energy &#8220;crisis.&#8221;  Pressured by worried constituents, governments are scrambling to invest public money in alternative fuels.  Unlike venture capitalists, who are motivated by profits and will see through faulty metrics, government &#8220;investors&#8221; are motivated by constituent pressures.  Those pressures are largely influenced by media reports.  Journalists are busy folks and will tend to believe (quite rationally, I suppose) that the information in a mandated securities filing is accurate.  Thus, we end up with all sorts of news stories about how major oil companies are producing at record levels, while their reported reserves are oh-so-small.  Politics takes over from there.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Michael Guttentag</title>
		<link>http://truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5441</link>
		<dc:creator><![CDATA[Michael Guttentag]]></dc:creator>
		<pubDate>Wed, 08 Feb 2006 17:39:07 +0000</pubDate>
		<guid isPermaLink="false">http://www.truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5441</guid>
		<description><![CDATA[A big vote of support for your argument:  â€œIf the goal of mandatory disclosure is to provide investors with an accurate picture of a companyâ€™s financial condition, then shouldnâ€™t the information disclosed be that by which the company judges its own financial health and upon which it bases operating decisions?â€?  This is what I have argued for elsewhere, and I think the existence of a commonly accepted standard for oil reserves makes the argument all the more plausible here.

If I may go further, you may ask why information in this form might not happen without regulatory intervention?]]></description>
		<content:encoded><![CDATA[<p>A big vote of support for your argument:  â€œIf the goal of mandatory disclosure is to provide investors with an accurate picture of a companyâ€™s financial condition, then shouldnâ€™t the information disclosed be that by which the company judges its own financial health and upon which it bases operating decisions?â€?  This is what I have argued for elsewhere, and I think the existence of a commonly accepted standard for oil reserves makes the argument all the more plausible here.</p>
<p>If I may go further, you may ask why information in this form might not happen without regulatory intervention?</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Bill Sjostrom</title>
		<link>http://truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5440</link>
		<dc:creator><![CDATA[Bill Sjostrom]]></dc:creator>
		<pubDate>Wed, 08 Feb 2006 16:33:11 +0000</pubDate>
		<guid isPermaLink="false">http://www.truthonthemarket.com/2006/02/08/accurately-disclosing-oil-reserves/#comment-5440</guid>
		<description><![CDATA[I assume oil companies publicly disclose reserves calculated using the alternative standards. Off hand, I can&#039;t think of an SEC regulation that would prevent them from doing so. It seems similar to the disclosure of pro forma earnings, which companies do all the time. Therefore, I suspect that capital is not being erroneously channeled.

I agree with your broader point that if the SEC metric is worthless, it should perhaps be changed.]]></description>
		<content:encoded><![CDATA[<p>I assume oil companies publicly disclose reserves calculated using the alternative standards. Off hand, I can&#8217;t think of an SEC regulation that would prevent them from doing so. It seems similar to the disclosure of pro forma earnings, which companies do all the time. Therefore, I suspect that capital is not being erroneously channeled.</p>
<p>I agree with your broader point that if the SEC metric is worthless, it should perhaps be changed.</p>
]]></content:encoded>
	</item>
</channel>
</rss>

