On Tuesday, April 29, 2014, Keith Higgins, the Director of the Division of Corporation Finance, released an eagerly awaited statement on the effect of the Court of Appeals decision on the conflict minerals rule. Two weeks ago, the Court of Appeals found that the conflict minerals rule violated the First Amendment when it required reporting … Continue Reading
Today, two SEC Commissioners issued a joint statement indicating that they believe that the effectiveness of the conflict minerals rule should be stayed pending the final outcome of the legal challenge because they believe that the district court could conclude that the entire conflict minerals rule is invalid. In part, they said: “The First Amendment concerns permeate … Continue Reading
April 18, 2014 – April 25, 2014 The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Sanders (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our … Continue Reading
Siliconware Precision Industries Co., Ltd. is the first company to file a Form SD, with a filing in the early morning hours of April 24, 2014. A Conflict Minerals Report is filed as an exhibit to the Form SD. The company files under the “seminconductors and related devices” SIC code. According to the company, no independent … Continue Reading
Last week, on April 14, the DC Circuit Court of Appeals issued a decision in the legal challenge of the conflict minerals rule and affirmed most of the provisions of the rule, but it found that portions of the SEC’s conflict minerals rule violated the First Amendment when they required that reporting companies report to the SEC and … Continue Reading
April 11, 2014 – April 18, 2014 The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Sanders (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our … Continue Reading
As you recall, shortly after the SEC issued the Conflict Minerals Rule, several trade groups challenged the rule in federal court. The trade groups challenged the SECs cost-benefit analysis, questioned the SECs discretionary choices, and claimed that certain requirements in the rule violate the First Amendment. Today, in a 2-1 decision, the D.C. Court of Appeals sided with the … Continue Reading
April 4, 2014 – April 11, 2014 The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Sanders (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our … Continue Reading
On April 7, 2014, the SEC issued a second set of FAQs on the conflict minerals rule which is presented as Frequently Asked Questions 13-21. Most of the new FAQs provide guidance on the Independent Private Sector Audit (IPSA), which very few companies will be required to provide for this first reporting year. But, a couple … Continue Reading
March 28, 2014 – April 4, 2014 The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Sanders (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our … Continue Reading
