SEC staff answers frequently asked questions about the conflict minerals rule
On 30 May, the SEC published answers by its staff to a dozen frequently asked questions relating to its rule requiring reporting companies under the Exchange Act to provide annual disclosures regarding conflict minerals. The disclosures are required if an issuer determines that conflict minerals are necessary to the functionality or production of products it manufactures or contracts to manufacture. Exchange Act Rule 13p-1 and Form SD set forth the disclosure requirements implementing Section 13(p) of the Exchange Act, which was added by Section 1502 of the Dodd-Frank Act…
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The decision of the US Court of Appeals has raised questions about how issuers should present their disclosures on conflict minerals under Exchange Act Rule 13p-1 and Form SD.
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Analysis from The Lawyer
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