View Authors May 2014
Although the SEC’s Conflict Minerals Rule (Rule) was adopted in August 2012, the requirements and implementation remain unsettled as the federal court challenge of the Rule continues. The SEC has spoken twice since April 29, 2014 regarding how it plans to implement the Rule. As companies work toward the filing of their conflict minerals disclosures by June 2, 2014, they also have to be aware of the real time changes and updates to the implementation of the Rule. This publication describes the recent actions by the SEC, the Motion for Stay filed by the trade associations challenging the Rule and the first Form SD filed, and offers insights as to what reporting companies should do between now and the June 2 filing date for conflict minerals disclosure.