SEC Issues Final Rules Under Dodd-Frank Act Regarding Conflict Minerals

The SEC has issued final rules (the "rules") implementing the conflict minerals disclosure required by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rules apply to issuers that (i) file reports with the SEC under Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934 (the "Exchange Act") and (ii) manufacture or contract to manufacture a product where conflict minerals are necessary to the functionality or production of such product. Such issuers are required to disclose annually on new Form SD whether any of those minerals originated in the Democratic Republic of the Congo or an adjoining country (the "Covered Countries"). Affected issuers must comply with these rules beginning with the year ending December 31, 2013, regardless of an issuer's fiscal year end, with the first reports on Form SD due May 31, 2014.