News & Analysis as of

Securities and Exchange Commission (SEC) Disclosure Requirements Conflict Mineral Rules

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due May 31, 2024

Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2024. The conflict minerals disclosure rules and related guidance have remained at...more

Cooley LLP

GAO reports on conflict minerals compliance in 2022

Cooley LLP on

The GAO has just issued its 2022 Report on Conflict Minerals, which examines companies’ conflict minerals compliance in 2022. As you probably know, the SEC’s conflict minerals rules were originally mandated by Congress in an...more

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due May 31, 2023

Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2023. The conflict minerals disclosure rules and related guidance have remained at a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due May 31, 2022

Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2022. The conflict minerals disclosure rules and related guidance have remained at...more

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due June 1, 2021

As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than June 1, 2021. The conflict minerals disclosure rules and related guidance...more

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due June 1, 2020, Despite COVID-19

As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than June 1, 2020. This remains true despite the impact of COVID-19, given that...more

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due May 31, 2019

As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2019. There have not been any notable regulatory updates related to the...more

Robinson+Cole Manufacturing Law Blog

The End of Conflict Minerals?

We have been talking about conflict minerals for years.  And, so have our manufacturing clients.  As covered previously in this blog, the conflict minerals laws and regulations are some of the most well known, but least...more

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due May 31, 2018

As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2018....more

Snell & Wilmer

Corporate Communicator - 2018 Annual Meeting Season

Snell & Wilmer on

Dear clients and friends, We present our traditional year-end issue of Snell & Wilmer’s Corporate Communicator to help you prepare for the upcoming annual report and proxy season. This issue highlights SEC reporting and...more

Stinson - Corporate & Securities Law Blog

Treasury Issues Plan to Streamline Capital Markets Regulation

Pursuant to Executive Order 13772, the Treasury Department has issued a report that identifies laws, treaties, regulations, guidance, reporting and record keeping requirements, and other government policies that promote or...more

Stinson - Corporate & Securities Law Blog

Preliminary Planning for the 2018 Proxy Season

Rule 14a-21(b) requires a say-on-pay frequency vote every six years. Many issuers included a frequency vote in their 2017 proxy because they were subject to the initial rules when they became effective for shareholders’...more

Cooley LLP

Blog: Conflict Minerals Benchmarking Study Analyzes Filings For 2016—Was There Any Progress?

Cooley LLP on

Development International has posted its most recent Conflict Minerals Benchmarking Study, analyzing the results of filings for the 2016 filing period. The study looked at filings submitted by the 1,153 issuers that had filed...more

Kramer Levin Naftalis & Frankel LLP

US House of Representatives Approves the Financial Choice Act

On June 8, the U.S. House of Representatives voted to approve the Financial CHOICE Act (FCA) primarily along party lines, 233-186. The FCA was introduced by Rep. Jeb Hensarling of Texas, and co-sponsored by 40 of his...more

Snell & Wilmer

Recent Developments with Respect to Conflict Minerals

Snell & Wilmer on

In the Spring 2017 issue of our Corporate Communicator, we included a brief discussion of the status of the conflict minerals rules contained in Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Exchange...more

BakerHostetler

Conflict Minerals Disclosure New SEC Guidance

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

Stinson - Corporate & Securities Law Blog

GAO Reports on 2015 Conflict Minerals Form SDs

GAO released an analysis of a generalizable sample of conflict minerals disclosures filed with SEC in 2015. The analysis found that an estimated 49 percent of companies in 2015 reported having determined whether the conflict...more

Stoel Rives LLP

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

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

Bracewell LLP

SEC Will Not Enforce Part of the Conflict Minerals Disclosure Rule

Bracewell LLP on

On Friday, April 7, 2017, the acting Chief of the Securities and Exchange Commission (the “Commission”) Michael Piwowar released a statement that the Commission will not recommend enforcement of certain parts of its Conflict...more

Parker Poe Adams & Bernstein LLP

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

Beveridge & Diamond PC

New Developments and Uncertainties for Conflict Minerals Disclosure

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

BCLP

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

BCLP 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

Stinson - Corporate & Securities Law Blog

Court Enters Final Judgment in Conflict Minerals Case

The United States District Court for the District of Columbia has entered a final judgment in the conflict minerals case. The final judgment is identical to the proposed judgment which we described previously....more

Stinson - Corporate & Securities Law Blog

Proposed Judgment in Conflict Minerals Case

Pursuant to a court order, the parties to the conflict minerals case have filed a proposed judgment after they advised the court no further proceedings were necessary. The text of the proposed judgment is as follows...more

Cooley LLP

Blog: Say Farewell To The Conflict Minerals Case, Nat’l Ass’n Of Mfrs. V. SEC

Cooley LLP on

The parties to the conflict minerals case have filed in the D.C. District Court a “Joint Status Report,” which requests that the Court enter a final judgment in accordance with the decision of the Court of Appeals. As a...more

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