On December 31, 2008, the United States Securities and Exchange Commission (the "SEC") adopted amendments to its oil and gas reporting requirements with the issuance of Final Reporting Release No. 78, Modernization of Oil and Gas Reporting. It was designed to modernize the oil and gas disclosure requirements of Regulation S-X and Regulation S-K in response to technological improvements in the industry over the past several years. Since its issuance, however, many questions have been raised regarding its application by participants in the industry. In response to these questions, the SEC clarified the final report in a question-and-answer format on October 26, 2009. This Commentary analyzes the guidelines provided by the SEC with respect to certain key disclosure issues and the impact that those issues may have on the ability of oil and gas companies to report their reserves.