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Jun 03, 2013

SEC publishes conflict minerals FAQs

The list includes guidance on packaging with reduced compliance obligations for some companies.

The US Securities and Exchange Commission on May 30 published its first 12 FAQs clarifying the Conflict Minerals Rule of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Most significantly, the FAQs provide guidance on packaging that dramatically reduces or eliminates the compliance obligations under the Conflict Minerals Rule for some issuers. The remaining FAQs further clarify various aspects of the Conflict Minerals Rule but will probably have minimal impact on the development and implementation of most conflict minerals compliance programs, since these FAQs largely restate guidance contained in the Adopting Release or confirm prevailing interpretations, according to Schulte Roth & Zabel, a law firm that conducts regular workshops on compliance with the Conflict Minerals Rule. The FAQs address only a small number of the many day-to-day questions and issues that companies are wrestling with as they implement the Conflict Minerals Rule within their organizations.

For the entire list of FAQs, see http://www.sec.gov/divisions/corpfin/guidance/conflictminerals-faq.htm

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