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Title

SEC Staff Announces Further Relief from Conflict Minerals Reporting Requirements
Client Memorandum

Created date

4/12/2017

On April 3, in the latest of a string of federal court rulings, the U.S. District Court in Washington, D.C. entered final judgment partially invalidating the SEC’s conflict minerals rule, on grounds that it violates the First Amendment to the extent that a company would be required to state that its products have not been found “DRC conflict free.”

In response to the ruling, the SEC staff issued updated guidance for companies preparing their Form SD filings for calendar year 2016, which are due May 31.