So many questions. Would they slash allowables across the board? Say, 25%? Moratorium on new wells? Would that trigger force majeure and toll current leases?
I'm not an attorney and this isn't legal advice, but force majeure will depend on the clause in the individual leases. The most common clause contains the language "circumstances beyond the reasonable control of the lessee." Also, in New York, the courts ruled in 2012 that a fracking moratorium wasn't enough to trigger the force majeure clause, so I'm sure that case will be pointed to a lot if the RRC throws out a moratorium. There's another 1993 Texas case that states that the forcing of a well to be shut-in by the RRC didn't trigger force majeure, either, but the circumstances around that case dealt with a producer who overproduced and were then ordered to shut-in to make up for it.
So, I'd say that if you had a producing well that was fully in compliance and the company was actively operating and marketing the oil and then gets shut down due to the RRC, the operator has a good shot at triggering the clause. Marginal wells and leases that go past their primary term without any operations done in good faith to cause a producing well, less of a chance.