Section 1502 of the Dodd-Frank Act added a new Section 13(p) to the Securities Exchange Act of 1934. Section 13(p) requires the SEC to promulgate disclosure and reporting regulations regarding the use of conflict minerals from the Democratic Republic of the Congo and adjoining countries.

In compliance with this Congressional mandate, the SEC issued these proposed regulations last December. In this February posting, Broc Romanek declared Section 1502 to be “the Dodd-Frank sleeper for disclosure lawyers”. The SEC’s extended comment period on its proposed regulations ended on March 2. Now, one California legislator is proposing to penalize companies who make (or fail to make) specified conflict mineral disclosures.