Stephen M. Quinlivan

Stephen M. Quinlivan

Stinson Leonard Street

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Is the Conflict Minerals Law Helping?

Those toiling away for the second required conflict minerals filings are sure to wonder whether the law is having any positive impact. Politico has an interesting article about a trip to the DRC in an attempt to answer that...more

5/18/2015 - Conflict Mineral Rules Reporting Requirements

NAM Files Supplemental Brief in Conflict Minerals Rehearing

The National Association of Manufactures, the Chamber of Commerce of the United States of America and the Business Roundtable have filed their supplemental brief in the conflict minerals rehearing. NAM et al ask the court to...more

12/30/2014 - Conflict Mineral Rules Disclosure Requirements Evidentiary Hearings NAM SEC

SEC Files Brief in Conflict Minerals Rehearing

The SEC has filed its brief in the conflict minerals rehearing. Amnesty International also filed its brief as intervenor and Free Speech for People filed an amicus brief....more

12/9/2014 - American Meat Institute Amnesty International Conflict Mineral Rules First Amendment Form SD SEC

Panel to Rehear Conflict Minerals Case

The United States Court of Appeals for the District of Columbia has granted the petition for a panel rehearing (as opposed to an en banc rehearing) in the conflict minerals case. The court asked the parties to file briefs...more

11/19/2014 - American Meat Institute Amnesty International Appeals Conflict Mineral Rules Department of Agriculture Disclosure Requirements First Amendment SEC Statement of Facts

Tulane Releases Study on First-Year Conflict Minerals Filings

The Payson Center for International Development of Tulane University Law School released a study analyzing the results of a June 2014 survey of issuers who filed the required Form SD. The study investigates the market impact...more

10/8/2014 - Conflict Mineral Rules Dodd-Frank Form SD Issuers Public Disclosure Surveys

NAM Says No Need for En Banc Rehearing in Conflict Minerals Case

Earlier, the United States Court of Appeals for the District of Columbia Circuit ordered the appellants in the conflict minerals case, NAM et al, to file a response to the SEC’s and Amnesty International’s petition for an en...more

9/15/2014 - Amnesty International Appeals Conflict Mineral Rules En Banc Review Manufacturers NAM SEC

Good News and Bad News: Commerce Department Publishes List of Conflict Minerals Processing Facilities

The good news is the Commerce Department published a list of ”all known conflict mineral processing facilities worldwide” as required by section 1502(d)(3)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act. ...more

9/8/2014 - Conflict Mineral Rules Dodd-Frank SEC

Conflict Minerals: Court Orders NAM to File Response to En Banc Rehearing Petition

The SEC, the perceived loser in the conflicts minerals case at the time, filed a petition for an en banc rehearing on May 29, 2014. NAM, the perceived winner at the time, stayed silent. After these many months, with public...more

8/29/2014 - Conflict Mineral Rules NAM SEC

Amnesty International Continues to Push for En Banc Rehearing in Conflict Minerals Case

Amnesty International has filed a supplemental brief which continues to advocate for a rehearing en banc in the conflict minerals case. The argument is this: American Meat Institute v. U.S. Department of Agriculture...more

8/20/2014 - American Meat Institute Amnesty International Conflict Mineral Rules Department of Agriculture Disclosure Requirements En Banc Review

New Decision Bodes Well for SEC in Conflict Minerals Case

In April 2014, the United States Court of Appeals for the District of Columbia held the SEC’s conflict minerals rule and statute embodied in Dodd-Frank violate the First Amendment to the extent the statute and rule require...more

7/30/2014 - Conflict Mineral Rules Dodd-Frank Enforcement Enforcement Actions First Amendment SEC

GAO Says Commerce Department Has Not Complied With Conflict Minerals Obligations

The Government Accountability Office, or GAO, has issued a report noting the SEC issued a rule in 2012 requiring certain companies to disclose the source and chain of custody of necessary conflict minerals in their products....more

7/7/2014 - Compliance Conflict Mineral Rules GAO SEC U.S. Commerce Department

SEC Commissioner Wants Dodd-Frank Wrapped Up

SEC Commissioner Kara M. Stein recently gave remarks on the status of required Dodd-Frank rulemakings. The pay ratio, claw back, conflict minerals and resources extraction rules didn’t really seem all that important to her...more

6/16/2014 - Conflict Mineral Rules Disclosure Requirements Dodd-Frank Rulemaking Process SEC SEC Commissioner

Report Indicates Armed Groups Cede Control of Conflict Minerals Mines in Congo

A report issued by the organization Enough Project indicates market changes spurred by the Dodd-Frank Act’s provisions on conflict minerals have helped to significantly reduce the involvement of armed groups in eastern...more

6/13/2014 - Conflict Mineral Rules Dodd-Frank Mining SEC

SEC Seeks Rehearing of Conflicts Minerals Decision

The SEC has filed documentation with the District of Columbia Court of Appeals seeking an en banc rehearing of the conflict minerals decision. The original decision found that one piece of the disclosure required by the...more

6/2/2014 - American Meat Institute Conflict Mineral Rules Disclosure Disclosure Requirements En Banc Review SEC USDA

Intel Files Conflict Minerals Report

The holy grail (at least so far) of conflict minerals precedents was filed with the SEC albeit perhaps too late for many issuers to wholesale change course. But still excellent for a final form check. ...more

5/23/2014 - Conflict Mineral Rules Intel NAM Reporting Requirements SEC

NAM’s Next Move In Conflict Minerals Case

Now that NAM et al’s emergency stay motion in the conflicts minerals case has been denied, the question is what happens next. Clues can be found in the briefing for the unsuccessful emergency stay motion....more

5/16/2014 - Conflict Mineral Rules Enforcement Actions First Amendment NAM SEC

NAM Motion For Emergency Stay Denied In Conflict Minerals Case

The United States Court of Appeals for the District of Columbia has issued a per curiam order denying NAM’s motion for an emergency stay of the conflict minerals rules. Looked like kind of a moonshot anyway. The order is...more

5/15/2014 - Conflict Mineral Rules First Amendment Motion To Stay NAM SEC

NAM Replies To SEC In Conflict Minerals Emergency Stay

NAM et al have filed their reply brief in the conflict minerals emergency stay hearing. Highlights, many of which are not new points, are...more

5/14/2014 - Conflict Mineral Rules Motion To Stay NAM SEC

Second Conflict Minerals Report Filed

The second Form SD and related conflicts minerals report has been filed. They are interesting documents but may still not be the holy grail of precedents because of, among other things, the use of terms like “Conflict Free...more

5/13/2014 - Conflict Mineral Rules First Amendment Form SD Manufacturers NAD SEC Supply Chain

SEC Response To NAM Motion For Stay Of Conflict Minerals Rules

I hope NAM et al are successful in their motion for a stay of the conflict minerals rules, but it certainly isn’t a slam dunk. The SEC has filed its response to the motion for emergency stay. ...more

5/12/2014 - Conflict Mineral Rules First Amendment Manufacturers NAM SEC

Court Schedules Briefing In Conflict Minerals Emergency Stay Motion

NAM et al’s original motion for an emergency stay in the conflict minerals case requested a decision by May 26, 2014, just ahead of the filing deadline for Form SD. The United States Court of Appeals for the District of...more

5/8/2014 - Appeals Conflict Mineral Rules Form SD Motion To Stay NAM SEC

NAM Files Court Motion For Stay Of Conflict Minerals Rules

NAM et al have filed an emergency motion for stay with the Court of Appeals in the conflict minerals case. As predicted, it is largely a replay of the arguments made when NAM asked the SEC for a stay....more

5/6/2014 - Conflict Mineral Rules Motion To Stay NAM SEC

NAM Likely Headed For Court After SEC Denies Full Stay Of Conflict Minerals Rules

The SEC has denied NAM’s motion for a full stay of the conflict minerals rules. As I indicated, it was somewhat of a hail Mary, but maybe a precondition to asking the court for relief. ...more

5/5/2014 - Conflict Mineral Rules First Amendment Manufacturers NAM SEC

NAM Throws A Hail Mary In Conflicts Minerals Case

When Commissioners Daniel M. Gallagher and Michael S. Piwowar released this Joint Statement on the Conflict Minerals Decision on April 28, 2014, I wondered where it would go. ...more

5/2/2014 - Conflict Mineral Rules Dodd-Frank First Amendment Manufacturers NAM SEC

Conflict Minerals — SEC Says File The Reports — But Don’t Confess Blood On Your Hands

At the core, the court’s first amendment objection to the conflict minerals rules was that by requiring issuers to state its products have not been found to be “DRC conflict free” it compelled an issuer to “confess blood on...more

4/30/2014 - Conflict Mineral Rules Reporting Requirements SEC

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