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Dodd-Frank

Conflict Minerals Update

by   |   October 28, 2011

The SEC has proposed rules mandated by the Dodd-Frank Act that would require new disclosures by public companies concerning conflict minerals that originated in the Democratic Republic of the Congo or an adjoining country.  Final rules have not yet been adopted.  However, some recent developments are noted below.

Recently the SEC held a public roundtable to address the agency’s required conflict minerals rulemaking under Section 1502 of the Dodd-Frank Act.  PLI’s Securities Law Practice Center has a summary of the roundtable.

Compliance Week outlines a study done at Tulane University, which notes that  the aggregate cost to comply with the Dodd-Frank Act’s conflict minerals rule, as it is currently proposed, could run as high as $7.93 billion, dwarfing the Securities and Exchange Commission’s $71.2 million estimate of the costs for companies to comply with the reporting requirement.

Finally, TheCorporateCounsel.net’s Proxy Season Blog highlights a memo outlining recent California legislation that requires public companies contracting with the State of California to ensure that their supply chains are free of “conflict minerals” sourced from the Democratic Republic of the Congo.

Check dodd-frank.com frequently for updates on the Dodd-Frank Act and other important securities law matters.