Last month, the SEC issued final rules concerning disclosure of (1) the use of conflict minerals and (2) payments made by resource extraction issuers to a foreign government or the U.S. federal government for the purpose of commercially developing oil, natural gas or minerals, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under the new rules, a new Form SD (“Specialized Disclosure”) will be used for issuers to report the use of conflict minerals and payments by resource extraction issuers to governments. Issuers generally will have 2013 to assess whether the new report will be required and to develop procedures for complying with the new disclosure requirements, since Form SD will be due starting May 31, 2014 and annually each May 31 thereafter.
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