SEC Issues Guidance on Conflict Minerals with One Year to Go

13 June 2013
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Key takeaways:

  • The SEC’s Division of Corporation Finance issued responses to FAQs on May 30, 2013, providing guidance on certain aspects of the conflict minerals rule
  • Of particular note, the FAQs provide further clarity on whether and when packaging and equipment are subject to the rule
  • Important interpretive issues and time consuming due diligence remain for many reporting companies. Implementation of compliance programs and diligence initiatives should not be delayed.