How To Implement Conflict Minerals Rule Requirements

Law360, New York (September 26, 2012, 2:58 PM EDT) -- As described in a recent Law360 article, the U.S. Securities and Exchange Commission’s newly enacted conflict minerals rule is “strict, onerous and vague.” Issuers subject to the rule will face potential Section 18 liability for false or misleading statements. The required supply chain inquiry will likely be expensive and burdensome: the SEC itself estimates an initial cost of $3 billion to $4 billion for all companies covered by the rule and an ongoing annual compliance expense of $200 million to $600 million.

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