Dodd-Frank's “Conflict Minerals” Provision: Expected to Impact Nearly Half of All U.S. Public Companies


UPDATE: SEC delays final rules until at least August, 2011

Tucked into the sweeping 2,200 page Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act” or the “Act”) is a provision that requires companies that file annual reports with the SEC to disclose in those reports specific information related to their resource supply chains and manufacturing processes.

Specifically, Section 1502 of the Act applies to companies that file Form 10-K, 20-F, or 40-F annual reports with the SEC and use so- alled “conflict minerals,” to disclose whether those minerals came from the Democratic Republic of the Congo (DRC) or an adjoining country. These reporting obligations apply if the role of these minerals is determined to be “necessary to the functionality or production of a product manufactured.”

Please see full Alert below for further information.

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