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SEC Responds to U.S. Court of Appeals Decision on Conflict Minerals Rule

05 May 2014

SEC Update

Both the Securities and Exchange Commission and its staff recently responded to the April 14 ruling of a federal appeals court that the SEC’s conflict minerals rule violates the First Amendment’s prohibition against compelled speech to the extent that it requires issuers to disclose in their Conflict Minerals Report filed with the SEC and to state on their website that any of their products have “not been found to be ‘DRC conflict free.’” The decision of the U.S. Court of Appeals for the District of Columbia Circuit, which is discussed in our SEC Update available here, has raised questions about how issuers should present their disclosures on conflict minerals under Exchange Act Rule 13p-1 and Form SD.

Read more: SEC Responds to U.S. Court of Appeals Decision on Conflict Minerals Rule

The team

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