Reporting Companies’ Conflict-Minerals Obligations Will Continue


A number of reporting companies are still working diligently to comply with their obligations to file the initial Form SD, by May 31, 2014, under the SEC’s conflict-minerals rule. As recently pointed out in a comment by Doug Harmon, however, the compliance “battle” will not cease with the filing of the Form SD in May. It will be an achievement for a reporting company to complete the work regarding the initial Form SD filing obligation. But a reporting company should be mindful that the assessment and filing obligation is an annual one. Therefore, among the efforts to assess and (as necessary) make this year’s filing, a reporting company should be focusing on:

  • Institutionalizing or formalizing information and processes or procedures that will be useful in its compliance efforts in future years, and
  • Identifying changes in its businesses or operations in the future that may change the results of this year’s work regarding the Form SD.

OUR TAKE: A reporting company should make an effort to evaluate and formalize its compliance work regarding this year’s Form SD to better enable the company to perform the necessary work for subsequent years.


What do you think?

The publications contained in this site do not constitute legal advice. Legal advice can only be given with knowledge of the client's specific facts. By putting these publications on our website we do not intend to create a lawyer-client relationship with the user. Materials may not reflect the most current legal developments, verdicts or settlements. This information should in no way be taken as an indication of future results.

Search Tips:

You may use the wildcard symbol (*) as a root expander.  A search for "anti*" will find not only "anti", but also "anti-trust", "antique", etc.

Entering two terms together in a search field will behave as though an "OR" is being used.  For example, entering "Antique Motorcars" as a Client Name search will find results with either word in the Client Name.


AND and OR may be used in a search.  Note: they must be capitalized, e.g., "Project AND Finance." 

The + and - sign operators may be used.  The + sign indicates that the term immediately following is required, while the - sign indicates to omit results that contain that term. E.g., "+real -estate" says results must have "real" but not "estate".

To perform an exact phrase search, surround your search phrase with quotation marks.  For example, "Project Finance".

Searches are not case sensitive.

back to top