Insight
On April 7, the SEC Division of Corporation Finance issued an interpretation that companies subject to paragraph (c) of Item 1.01 of Form SD may file only the disclosure required under paragraphs (a) and (b). The interpretation, which results from litigation challenging the conflict minerals rules, makes it clear that companies remain obligated to comply with paragraphs (a) and (b) and that further changes in the rules or how they are interpreted are possible.
Please contact David Scileppi or Bob Lamm if you have any questions.
