Yesterday, the SEC announced that the Notice required by the Iran Threat Reduction and Syria Human Rights Act of 2012 (Act), which was signed into law on August 10, 2012, should be filed on EDGAR. This new EDGAR form is called IRANNOTICE, and it will be publicly available on EDGAR upon filing with the SEC. The SEC expects this EDGAR form to be released on January 14, 2013.
Section 219 of the Act added a new subsection (r) to Section 13 of the Securities Exchange Act of 1934 to require an issuer that files Exchange Act periodic reports under Section 13(a) of the Exchange Act to disclose in its annual or quarterly report whether during the period covered by the report the issuer or any of its affiliates knowingly engaged in certain specified activities, including contacts with or support for Iran. Section 13(r) also requires an issuer that describes such activity in a periodic report to concurrently file with the SEC a notice, designated as IRANNOTICE by the SEC, that identifies the issuer and indicates that disclosure of the activity was included in its periodic report.