Form SD

News & Analysis as of

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

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...more

Corporate Communicator - Summer 2014

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010) added Section 13(p) to the Securities Exchange Act of 1934, as amended (the Exchange Act), mandating that the SEC adopt regulations relating...more

SEC Conflict Minerals Reporting Update

The first reports on Securities and Exchange Commission Form SD, regarding the presence of so-called "conflict minerals" in products manufactured or contracted for manufacture by SEC reporting companies, are due June 2, 2014....more

Courtroom Battle Over Conflict Minerals Rules is Over, June 2nd Filing Deadline Rapidly Approaching

On May 14, 2014, the US Court of Appeals for the District of Columbia denied the emergency motion filed by the National Association of Manufacturers to stay the effectiveness of the SEC’s conflict minerals rules. The first...more

Deadline Looms For Conflict Mineral Disclosure Requirements: Update For Suppliers Of Reporting Companies

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") addressed concerns that proceeds from the trade and exploitation of certain minerals originating in several central African...more

Court Strikes Portions of Conflict Minerals Rule, But June 2 Filing Deadline Stands

A federal appeals court this week denied an emergency request by business groups to delay the June 2 deadline requiring companies to file a conflict-minerals disclosure report (Form SD) if their products contain minerals from...more

Updated: No Stay of SEC’s Conflict Minerals Rules

Court denies emergency motion for a stay. By order issued on May 14, 2014, the U.S. Court of Appeals for the District of Columbia denied the appellants’ emergency motion for a stay of the Securities and Exchange...more

Ten Tips to Develop a Practical Conflict Minerals Approach for 2014

As you sit at your desk waiting for any guidance regarding what your Conflict Minerals Report should look like, you may allow yourself to think about June 3, 2014, the day after companies are required to file their Form SD...more

SEC Staff Guidance: Companies Must File Conflict Minerals Disclosure With Modifications

In response to the U.S. Court of Appeals for the District of Columbia Circuit’s recent opinion upholding the conflict minerals statute and rule, but finding First Amendment violations, the Director of the SEC’s Division of...more

Possible Future Stay of SEC’s Conflict Minerals Rules

Stay of conflict minerals disclosure may be decided by May 26, 2014. On May 7, the U.S. Court of Appeals for the District of Columbia Circuit ordered the briefing schedule that was requested by the National Association...more

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

Conflict Minerals Filing Tips – Deadline Approaching

What you need to know: Public companies are required to submit their conflict minerals filings by June 2nd. SEC guidance issued after a recent federal appeals court decision has effectively eliminated the...more

This Week In Securities Litigation (Week ending May 9, 2014)

The Commission issued an order which stayed the small segment of its controversial conflict mineral rule which the Court of Appeals concluded violated the First Amendment. The order does not impact the bulk of the rule. This...more

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

Conflict Minerals Rule Update: NAM Motion for Stay

As mentioned below, on April 29, 2014, the National Association of Manufacturers (NAM), Chamber of Commerce and Business Roundtable filed a motion for stay with the SEC. The motion requested that the SEC stay its final...more

Division of Corporation Finance Releases Guidance on Conflict Minerals Rule

The director of the SEC's Division of Corporation Finance issued a public statement yesterday advising issuers to satisfy Form SD filing obligations on a timely basis notwithstanding the recent appellate ruling in National...more

SEC Issues Statement Regarding the Status of the Conflict Minerals Rule

Today the SEC issued a Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule. (See our earlier blogs regarding the conflict minerals rule and the legal challenge thereto). Form SD...more

Conflict Minerals – Yet Another Update

If ever there was an SEC rule that refused to slip quietly into the books, it’s conflict minerals disclosure. With the May 31st Form SD filing deadline fast approaching, three things are happening: Companies are focusing for...more

Mandate Withheld In Conflicts Minerals Case

In a little known action, the Clerk of Court of the Unites States Court of Appeals for the District of Columbia issued an order in the conflicts minerals case to withhold issuance of a mandate until seven days after...more

Conflict Minerals…the Legal Saga Continues…

Yesterday, the United States Court of Appeals for the District of Columbia issued its opinion on the conflict minerals legal challenge. The ruling rejected a number of the petitioner’s arguments, but agreed with the...more

Appeals Court Opinion Changes Conflict Minerals Rules Compliance Landscape

On Monday, April 14, 2014, the U.S. Circuit Court of Appeals for the District of Columbia (the DC Circuit) struck down part of the federal rules requiring publicly traded companies to report on their use of “conflict...more

Securities Update - March 2014

In December 2013, the Staff of the Securities and Exchange Commission’s Division of Corporation Finance issued to Congress its “Report on Review of Disclosure Requirements in Regulation S-K” (the S-K Study) that originally...more

Closing the Conflict Minerals Loop–Ongoing Compliance

By now you’ve heard all you want to hear about complying with the new conflict minerals disclosure rules. You know that public companies that manufacture a product, or contract to manufacture a product, for which a conflict...more

7 Tips for Complying with the Conflict Minerals Rule

With the recent publication of Form SD, the disclosure form that all companies subject to the Conflict Minerals Rule must file with the Securities and Exchange Commission (SEC), it is a good time to brush up on the Rule’s...more

SEC Update

PROXY SEASON PREVIEW - Say-on-Pay and Equity Compensation Plans - Although say-on-pay votes are only advisory in the United States, they will likely continue to be a focus for many companies in the upcoming 2014...more

38 Results
|
View per page
Page: of 2