Conflict Minerals: SEC Position on Non-Metallic Forms of Tin

more+
less-

Shortly before the filing deadline for the first conflict minerals filings on Form SD, it became known that the SEC believed non-metallic forms of tin are not conflict minerals because non-metallic forms of tin are “chemically distinct from the metal derivatives themselves.” Documentation of the SEC position has been scant. However, a letter outlining the discussions by a firm that participated in the discussions has appeared on the SEC website which is some help in verifying the position.

We note however that the letter was uploaded to the comments section on the proposed conflict minerals rules which could mean it was not necessarily vetted in the same manner as more authoritative SEC staff positions.

Our thanks to The Elm Consulting Group International LLC for pointing this out.

 

Topics:  Compliance, Conflict Mineral Rules, Form SD, SEC

Published In: General Business Updates, Securities Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Stinson Leonard Street - Dodd-Frank and the Jobs Act | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »