The SEC's Delayed Rule-Making And Implications For Corporate Conflict Minerals Reports

This post, authored by Sarah A. Altschuller and Gwendolyn W. Jaramillo, was originally published, in excerpted form, by The Elm Consulting Group.

The U.S. Securities and Exchange Commission ("SEC") failed to issue a final rule on conflict minerals regulations before the end of 2011, and companies still await clear guidance on the scope of Section 1502 and the nature of the relevant reporting requirements. In an announcement regarding "upcoming activity" related to the implementation of Dodd-Frank, the SEC has now indicated that the final rule for Section 1502 will be adopted between January and June 2012. Notably, the SEC's announcement indicates that "this is an estimated timeline and may be subject to change." The final rule was originally scheduled to be issued no later than April 15, 2011.