On Friday, the SEC and Amnesty International each filed petitions seeking a rehearing en banc of the August 2015 panel opinion of the U.S. Court of Appeals for the District of Columbia Circuit regarding the conflict minerals...more
As noted in this Law 360 article and in this thecorporatecounsel.net blog , on Friday, the SEC filed a Notice of Proposed Rulemaking in the U.S. District Court for the District of Massachusetts in connection with Oxfam...more
Earlier, the United States Court of Appeals for the District of Columbia Circuit ordered the appellants in the conflict minerals case, NAM et al, to file a response to the SEC’s and Amnesty International’s petition for an en...more
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
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
I hope NAM et al are successful in their motion for a stay of the conflict minerals rules, but it certainly isn’t a slam dunk. The SEC has filed its response to the motion for emergency stay. ...more
On May 2, 2014, the SEC issued an order partially staying its Conflict Minerals Rule. Essentially, the order reiterates the SEC’s April 29, 2014, guidance that the Commission will not require companies subject to the conflict...more
The SEC has denied NAM’s motion for a full stay of the conflict minerals rules. As I indicated, it was somewhat of a hail Mary, but maybe a precondition to asking the court for relief. ...more
The SEC issued guidance on its interpretation of the U.S. Court of Appeals for the D.C. Circuit’s recent decision that certain portions of the SEC’s conflict minerals reporting requirements violate the First Amendment...more
When Commissioners Daniel M. Gallagher and Michael S. Piwowar released this Joint Statement on the Conflict Minerals Decision on April 28, 2014, I wondered where it would go. ...more