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SEC Posts Small Entity Compliance Guide Regarding Conflict Minerals Disclosure

On November 13, the Division of Corporation Finance of the Securities and Exchange Commission posted A Small Entity Compliance Guide (Compliance Guide) on its website related to the final rule implementing disclosure and reporting requirements regarding the use by issuers of conflict minerals from the Democratic Republic of the Congo (DRC) and adjoining countries (collectively, the Covered Countries). “Conflict minerals” are tantalum, tin, gold, tungsten, their derivatives, or any other minerals or their derivatives determined by the US Secretary of State to be financing conflict in the Covered Countries. The final rule applies to issuers who file reports with the SEC under Sections 13(a) or 15(d) of the Securities Exchange Act of 1934 and for which conflict minerals are “necessary to the functionality or production of a product to be manufactured by the company” or “contracted to be manufactured.” Conflict minerals disclosures will be filed on new Form SD be due on May 31 of each year, beginning May 31, 2014, for calendar year 2013. See the August 24, 2012, edition of Corporate and Financial Weekly Digest.

The Compliance Guide provides a brief overview of the final rules and includes a helpful flowchart from the final rules, but does not provide substantive interpretation of the final rules.

Click here to view the Compliance Guide.

©2014 Katten Muchin Rosenman LLP

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