Analysis released by the Tulane University Law School has found that aggregate cost to comply with the Dodd-Frank Act’s Conflict Minerals rule, as it is currently proposed, could run as high as $7.93 billion, dwarfing the Securities and Exchange Commission’s $71.2 million estimate of the costs for companies to comply with the reporting requirement.
The study entitled “A Critical Analysis of the SEC and NAM Economic Impact Models and the Proposal of a Third Model in View of the Implementation of Section 1502 of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act” was prepared at the request of Senator Dick Durbin of Illinois, a co-sponsor of the conflict minerals provision in Dodd-Frank.

