On August 22, 2012, the Securities and Exchange Commission adopted rules (the "Conflict Minerals Rules") implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which relates to reporting requirements regarding conflict minerals originating in the Democratic Republic of the Congo and adjoining countries. The new rules impose additional disclosure obligations on issuers that use “conflict minerals” in their products. Affected issuers are required to comply with the Conflict Minerals Rules beginning with the year ended December 31, 2013 by filing their conflict minerals disclosure and, if required, conflict minerals report on new Form SD by May 31, 2014. This Client Alert highlights the principal provisions of the Conflict Minerals Rules and the key changes from the proposed rule issued by the SEC on December 15, 2010, as announced at the SEC open meeting on August 22, 2012 at which the Conflict Minerals Rules were adopted. We intend to publish a more detailed client memorandum analyzing the Conflict Minerals Rules as soon as the text of the final rule is formally published.
View full memo, "SEC Adopts Dodd-Frank Conflict Minerals Rules"