News & Analysis as of

Form SD

Conflict Minerals Disclosure New SEC Guidance

by BakerHostetler on

On April 7, 2017, the Securities and Exchange Commission ("SEC") Division of Corporate Finance (the "Division") indicated that it will not recommend enforcement of the conflict minerals source and chain of custody due...more

Blog: Letter From Six Senators Challenges Authority Of Acting SEC Chair On Conflict Minerals No-Action Position

by Cooley LLP on

It’s not only the NGOs that have expressed their dismay at the no-action position taken by Corp Fin and Acting SEC Chair Michael Piwowar with regard to compliance by companies with the conflict minerals rule. In this April 26...more

Blog: GAO Issues Annual Report Showing Only Slight Progress In Disclosures On Conflict Minerals

by Cooley LLP on

The GAO has recently issued its third annual report on conflict minerals. The GAO is required by Dodd-Frank to report annually on the effectiveness of the SEC’s conflict minerals rule in promoting peace and security in the...more

In Case You Missed It - Interesting Items for Corporate Counsel - April 2017

by Stoel Rives LLP on

A host of things happened in the last few months regarding Conflict Minerals, although likely not much that will affect what a public company reports on its Form SD, due May 31. (Spoiler alert: The same thing companies have...more

Conflict Minerals Update – SEC Releases Guidance Following District Court Decision

by White & Case LLP on

On April 3, 2017, the US District Court for the District of Columbia (the "Court") entered a final judgment in National Association of Manufacturers, et al. v. Securities and Exchange Commission,1 ruling that Section 1502 of...more

Corporate and Financial Weekly Digest - Volume XII, Issue 14

SEC/CORPORATE - SEC Division of Corporation Finance Provides Update on Conflict Minerals Rule - On April 7, the Securities and Exchange Commission Division of Corporation Finance (the Division) issued a statement...more

SEC’s Division of Corporate Finance Issues Statement on Conflict Minerals Disclosure Requirements

Ruling & Enforcement: Conflict Minerals’ Disclosure - On April 3, 2017, the U.S. District Court for the District of Columbia entered a final judgment in favor of the National Association of Manufacturers, declaring that...more

Blog: Senate Hearing On Conflict Minerals Law Reveals Common Theme

by Cooley LLP on

On April 5, just prior to the release of Corp Fin’s Updated Statement on conflict minerals, the Senate Subcommittee on Africa and Global Health Policy held a hearing on the effects on the Democratic Republic of the Congo of...more

Blog: Responses to Corp Fin’s Updated Statement on Conflict Minerals

by Cooley LLP on

A number of NGOs have issued statements emphatically rejecting Corp Fin’s Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule and the Acting Chair’s separate Statement on conflict...more

SEC Issues Updated Statement on Conflict Minerals Rule

by Ropes & Gray LLP on

On Friday afternoon, the SEC’s Division of Corporation Finance issued an Updated Statement on the Conflict Minerals Rule (the “Rule”). An updated Statement was widely anticipated. Earlier in the week, on April 3rd, the U.S....more

Conflict Minerals - What Just Happened and What Didn’t

The conflict minerals saga continues. Background - In April 2014, the Court of Appeals for the D.C. Circuit in National Association of Manufacturers v. SEC held that the conflict minerals rule’s requirement that...more

SEC Provides Additional Relief for Conflict Minerals Disclosures: What Should Covered Public Companies File on May 31st?

by Locke Lord LLP on

On April 7, 2017, the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) issued a statement on the effect of the recent court decisions in National Association of Manufacturers v. SEC...more

New Developments and Uncertainties for Conflict Minerals Disclosure

by Beveridge & Diamond PC on

The Securities and Exchange Commission (SEC or Commission) Division of Corporate Finance issued a new statement adding some uncertainty to company obligations and enforcement exposure under the SEC conflict minerals rule...more

SEC Staff Issues New Guidance on Conflict Minerals Rule for 2017 Filings

by Bryan Cave on

Late Friday, April 7, the SEC issued two statements relating to the conflict minerals rule which reflect a significant change in the staff’s guidance for public companies. The upshot of these statements is that the staff...more

SEC Staff Relaxes Conflict Minerals Reporting

Effective immediately, the SEC staff has relaxed conflict minerals reporting requirements by public companies. The change was triggered by the entry of a final judgment in the conflict minerals case. ...more

Blog: Corp Fin Provides Relief On Conflict Minerals In Light Of Final Judgment In National Association Of Manufacturers V. SEC

by Cooley LLP on

On April 7, 2017, in light of the entry of final judgment by the D.C. District Court in National Association of Manufacturers v. SEC, Corp Fin issued an Updated Statement on the Effect of the Court of Appeals Decision on the...more

Case Closed! – The Conflict Minerals Rule Litigation Is Over, but the Drama Continues

by Ropes & Gray LLP on

After 1,627 days and enough law firm memos to deforest a small country, the litigation relating to the Conflict Minerals Rule came to an end yesterday. In this Alert, we discuss what this means for calendar year 2016...more

Blog: Final Judgment Entered In Conflict Minerals Case, National Association Of Manufacturers V. SEC

by Cooley LLP on

Today, the D.C. District Court entered final judgment in National Association of Manufacturers v. SEC, holding that Section 1502 of Dodd-Frank and Rule 13p-1 and Form SD, Conflict Minerals, violate the First Amendment to the...more

Corporate Communicator - Spring 2017 - Recent Developments Regarding the Conflict Minerals Reporting Requirements

by Snell & Wilmer on

On January 31, 2017, Michael Piwowar, Acting Chairman of the Securities and Exchange Commission (the “SEC”), issued two Statements regarding the current status of guidance on and implementation of the conflict minerals rules....more

More Conflict Minerals Drama

Well, it wouldn’t be February without a “helpful” reminder that Form SD filings are due on May 31st and a new development that casts confusion over the process. This year, the confusion comes in the form of last week’s...more

Will Congress Deep Six The SEC’s Resource Extraction Rule?

by Allen Matkins on

In December of last year, I wrote about how the Securities and Exchange Commission’s Resource Extraction Rule might meet an untimely end. See There’s Still Time For Congress To Void The SEC’s Resource Extraction Rule (Dec....more

Blog: So What Should We Do About Conflict Minerals Compliance For Next Year?

by Cooley LLP on

As of now, Forms SD and conflict minerals reports are still due on May 31, 2017. With all the discussion, in light of the election results, of rolling back legislation and regulations, through the Financial CHOICE Act and...more

GAO Says Companies Face Continuing Challenges in Determining Whether Their Conflict Minerals Benefit Armed Groups

GAO noted in a recent report that as a result of country-of-origin inquiries, an estimated 19 percent more companies that filed Form SD with the SEC reported that they knew or had reason to believe they knew the source of the...more

Blog: Consultants Report On Conflict Minerals Due Diligence And Disclosure For 2015. But Has It Made A Difference For The DRC?

by Cooley LLP on

Two consulting firms, Assent Compliance and Source Intelligence, have published their studies on conflict minerals (tin, tantalum, tungsten and gold) reporting for 2015, the third year of required SEC reporting. For 2015,...more

SEC Adopts Payment Disclosure Rules for Companies Engaged in Resource Extraction

by BakerHostetler on

The U.S. Securities and Exchange Commission (the “SEC”) has adopted new rules which require “resource extraction issuers” to disclose annually the type and amount of payments that they (or their subsidiaries or entities under...more

85 Results
|
View per page
Page: of 4
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
Feedback? Tell us what you think of the new jdsupra.com!