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Dodd-Frank

Ignore the First Conflict Minerals Filing

by   |   April 27, 2014

Securities lawyers eagerly await the first (or the first few) new filings required by law to learn (and of course copy) from them.  So the first conflict minerals filing to hit Edgar last week was eagerly anticipated, and immediately over analyzed.

Broc Romanek at TheCorporateCounsel.net reported reader reaction ranging from “If this is the baseline, we are looking to be in good shape,” to “Good example of “what not to do”” to “This thing is totally bizarre.”

For the reasons set forth in this blog, we don’t think issuers will follow this as precedent.

So one lesson learned is never be the first to file anything new early.

We are hoping the second filing is more instructive.

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