SEC Issues Statement On Conflict Minerals Rule

On April 30, 2014, the U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance issued a statement on Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the conflict minerals rule) reaffirming the need for companies to complete their due diligence efforts and make the required reporting by June 2, 2014, the deadline for the first round of reporting on 2013 activity.  The SEC statement was issued in response to the D.C. Circuit Court's April 14, 2014, decision striking down the requirement that companies publicly describe whether or not their products are "conflict free" on free speech grounds.  The SEC statement further removes the need for companies to undertake independent private sector audits, clarifying that such audits are required only if companies voluntarily claim their products to be "conflict free."