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

Stinson - Corporate & Securities Law Blog
Contact

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 “chemically distinct from the metal derivatives themselves.” Documentation of the SEC position has been scant. However, a letter outlining the discussions by a firm that participated in the discussions has appeared on the SEC website which is some help in verifying the position.

We note however that the letter was uploaded to the comments section on the proposed conflict minerals rules which could mean it was not necessarily vetted in the same manner as more authoritative SEC staff positions.

Our thanks to The Elm Consulting Group International LLC for pointing this out.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Stinson - Corporate & Securities Law Blog | Attorney Advertising

Written by:

Stinson - Corporate & Securities Law Blog
Contact
more
less

Stinson - Corporate & Securities Law Blog on:

Reporters on Deadline

"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:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.