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A Final Conflict Minerals Obstacle Awaits: Form SD

Joe Mont | March 4, 2014

So much work has been put into vetting suppliers and assessing products for compliance with new conflict minerals disclosure requirements that many companies may have not yet fully considered the actual filing protocol that is the end game for those supply chain reviews.

When companies do crack into the Securities and Exchange Commission's new Form SD—a new form created for conflicts minerals reporting and other “special disclosures”—it may feel unfamiliar. Rather than straightforward quantitative and check-the-box reporting, the atypical form asks for narratives and open-ended discussion of the issue.

Companies may also be unprepared for the level of inspection the SEC may bring to the forms.  “Companies are so focused on trying to meet the bare minimum requirements of the law, I don't think they have necessarily thought ahead to the level of scrutiny...

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