SEC Issues Proposed Rules Implementing Dodd-Frank Act – Reporting Obligations Regarding Conflict Minerals, Mine Safety and Payments by Resource Extraction Issuers

On December 15, 2010, the U.S. Securities and Exchange Commission (SEC) proposed rules to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Act) dealing with new reporting obligations regarding use of conflict minerals originating in the Democratic Republic of the Congo and adjoining countries, mine safety, and payments to government entities in connection with the commercial development of oil, natural gas or minerals.¹ This Update discusses key aspects of the proposed rules and highlights important questions regarding the proposed rules raised by the SEC for comment. The deadline for persons wishing to submit comments to the SEC on the proposed rules is January 31, 2011. Readers are encouraged to review our previous Update, " New Reporting Obligations Imposed on Mining Companies Under the Dodd-Frank Act", for background on the statutory provisions of the Act.