Deal Diary

On January 31, 2017, Acting Chairman of the Securities and Exchange Commission (SEC), Michael S. Piwowar, issued two statements calling for comments on the SEC’s enforcement of the conflict minerals reporting requirements of the Dodd-Frank Act. Congress implemented the conflict minerals reporting requirements in an effort to reduce funding to armed groups that commit human rights abuses and contribute to conflict in the Democratic Republic of Congo (DRC).

On May 2, 2014, the SEC issued an order partially staying its Conflict Minerals Rule. Essentially, the order reiterates the SEC’s April 29, 2014, guidance that the Commission will not require companies subject to the conflict minerals reporting requirements to state in their conflict minerals disclosures whether or not their products are “DRC conflict free” in light of the U.S. Court of Appeals for the District of Columbia’s holding that the Rule’s compelled designation of products as not “DRC Conflict Free” is unconstitutional. To read the full order, click here.