SEC's Final Rules on Conflict Minerals Disclosure Expected to Have Broad Impact

Cooley Alert

On August 22, 2012, the SEC, by a vote of three to two, adopted final regulations, mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, governing public company disclosure of the use of "conflict minerals" originating in the Democratic Republic of the Congo and adjoining countries. Conflict minerals are used in, or in the manufacture of, a wide range of electronic products, including laptops, mobile phones, PDAs, DVD players, digital cameras, gaming devices and televisions, as well as in medical devices, airplanes, cars, machine tools, jewelry, packaging for food products and a whole host of other products. As a result, these new rules are likely to have a surprisingly broad impact.

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Related Contacts
Kenneth Guernsey Partner, San Francisco
Cydney Posner Special Counsel, San Francisco
Sam Livermore Partner, San Francisco
Nancy Wojtas Partner, Palo Alto
Brent Siler Partner, Washington, DC
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