In our One-Hour Briefing presenting our thoughts on key issues for 2016 Form 10-K’s we discussed Conflict Mineral Reporting. Companies need to continue to refine their reporting processes as they gain experience with the rule and also watch for developments in the continuing legal challenges to the rule.
The short and sweet news here is that not a lot has changed since last year. That said, since this is a calendar year reporting requirement for all companies with a May 31 due date, there is time for change to occur before the due date.
One are that is not different is that because of the April 2014 court decision, issuers are still not required to report whether any of their products have “not been found to be DRC conflict free”. You can review the SEC Order for the Partial Stay of the rule at:
Corp Fin issued a Statement about the Court of Appeals decision which is at:
And there are SEC FAQ’s available at:
The FAQ’s do provide some process guidance, but the bottom line is that this area is still evolving.
As always, your thoughts and comments are welcome!
PS You can review the Form 10-K Tune-up Briefing and obtain CLE and CPE credit at: