The US Securities and Exchange Commission has adopted the final rule regarding disclosure of the use of conflict minerals that originated from the Democratic Republic of the Congo or an adjoining country. The centerpiece of the final conflict minerals rule is Form SD, a new form created specifically for specialized disclosures. Determining whether, and to what extent, a company is required to make conflict minerals disclosure involves a complex three-step process, and gathering the information necessary to comply with the rule can be time-consuming. Although the first Form SD will not be due until May 31, 2014, it will need to contain information with respect to the entire calendar year beginning January 1, 2013.
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