Beveridge & Diamond

SEC Announces Delay of Final Conflict Minerals Regulations

Beveridge & Diamond, P.C., April 11, 2011

The Securities and Exchange Commission (“SEC”) has announced that it will not publish its final regulations implementing section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) concerning conflict minerals before the statutory deadline of April 15, 2011.  According to the SEC’s recently published timeline for its implementation of the Dodd-Frank Act, the Commission will finalize the conflicts minerals regulations sometime between August and December 2011.  The SEC’s timeline is available at  The delayed timeline suggests that the SEC needs more time to consider potential revisions to the proposed rule in light of the numerous substantive comments that were submitted by industry and others during the comment period.

This delay will provide companies with fiscal years beginning between April 15 and the SEC’s final regulations with additional time to prepare for their obligations because the disclosure, due diligence, and reporting requirements are effective with respect to the company’s activities in the first full fiscal year following the SEC’s promulgation of final regulations.  On the other hand, those with fiscal years that begin soon after the SEC finalizes the regulations will have less time to prepare, which could be difficult if the final regulations differ in significant respects from the proposed regulations.

More information on the conflict minerals provisions of the Dodd-Frank Act is available at  Additional details on the SEC’s proposed regulations issued in December 2010 are available at

For more information, please contact Paul Hagen at (202) 789-6022 or, Russ LaMotte at (202) 789-6080 or, or Bethany French at (202) 789-6042 or





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