The Securities and Exchange Commission (the Commission), on
August 22, 2012, adopted a final rule implementing disclosure
requirements for reporting issuers that use "conflict
minerals" originating in the Democratic Republic of the Congo
or its adjoining countries (Covered Countries).
Under newly adopted Rule 13p-1, an issuer that determines
conflict minerals are "necessary to the functionality or
production of a product manufactured" by the issuer will be
required to file a specialized disclosure report on new Form SD.
The Commission's adopting release can be found at http://www.sec.gov/rules/final/2012/34-67716.pdf.
All issuers required to file Form SD under the final rule must
do so on a calendar-year basis by May 31 of the following year. The
first report, covering calendar year 2013, must be filed by May 31,
2014. In a change from the proposed rule, the specialized
disclosure report and, if required, the Conflict Minerals Report
must be "filed" -- not
