SEC’s “Conflict Minerals” Rules Delayed

Photo by Swamibu. Some rights reserved.

A recent Client Alert from King & Spalding reminds us that regulations under Section 1502 of the Dodd-Frank Act – which were originally expected to be adopted no later than April 15, 2011 – will now likely be delayed until August 2011.

Section 1502, “Conflict Minerals,” requires public companies to disclose:

“whether any conflict minerals that are necessary to the functionality or production of a product of the person, as defined in the provision, originated in the Democratic Republic of the Congo or an adjoining country and, if so, to provide a report describing, among other matters, the measures taken to exercise due diligence on the source and chain of custody of those minerals, which must include an independent private sector audit of the report that is certified by the person filing the report.” –

King & Spalding predicts that the requirements could apply to up to 6,000 out of 13,000 public companies. This is due to “the widespread use of conflict minerals, and the SEC’s application of the disclosure requirements to both companies that directly manufacture products and to companies that contract for the manufacture of their products.”

Want to be among the first to know when the final rules come out? Check out Knowledge Mosaic’s new & improved Dodd-Frank Tracker, where you can sign up to be alerted on Dodd-Frank related rulemaking.

One response to this post.

  1. […] background on the conflict minerals provisions, check out some of our previous posts. And don’t forget to check out the GAO report for more details on the delays. Share […]


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