Summary
Recently, the Securities and Exchange Commission (the
"SEC") adopted final rules implementing the
"conflict minerals" disclosure requirements in Section
1502 of the Dodd-Frank Wall Street Reform and Consumer Protection
Act (the "Dodd-Frank Act").1 Section 1502 of
the Dodd-Frank Act was enacted by Congress in order to impair the
financing of the conflict in the Democratic Republic of Congo
("DRC") and adjoining countries (the "Conflict
Countries")2, which has been effectuated
significantly by the trade of conflict minerals.
Section 1502 of the Dodd-Frank Act required the SEC to adopt
regulations requiring persons to annually disclose their use of
conflict minerals that originated in the Conflict Countries. The
SEC has adopted a new Form SD to be filed3 by covered
issuers on May 31 of each year (beginning on May 31, 2014 for the
2013 calendar year) covering the period of the prior calendar year,
regardless of when the issuer's fiscal year ends.4
The final
