SEC Adopts Final Conflict Minerals Disclosure Rules

On August 22, 2012, the Securities and Exchange Commission (the "SEC") adopted final rules to implement Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act"). Section 1502 was adopted as a result of concerns of members of Congress that the proceeds from the exploitation and trade of certain minerals originating in the Democratic Republic of the Congo (the "DRC") and adjoining countries (together, the "Covered Countries") are helping to finance violence, particularly sexual- and gender-based violence, in the Covered Countries giving rise to a humanitarian crisis. Section 1502 of the Act amended the Securities Exchange Act of 1934 (the "Exchange Act") to add new Section 13(p) which requires the SEC to promulgate new disclosure standards for issuers concerning their use of these minerals (the "Conflict Minerals Rules"). As promulgated, the minerals covered by the rules include columbite-tantalite (coltan), cassiterite, gold, wolframite,