In the last two weeks, there have been more than a few articles and law firm memos written on the SEC’s FAQs relating to the Conflict Minerals Rule. Many of the articles and memos recite the FAQs. Others provide a brief discussion of them. Most are calling the FAQs the only guidance from the SEC since the Release last August. But, a careful read of the SEC’s Reply Brief filed in the legal challenge gives additional insight into how the SEC might interpret certain elements of the Conflict Minerals Rule.
We’ve now put all this guidance into one place. Squire Sanders’ widely-recognized Interactive Flowchart, adapting the SEC’s flowchart and annotating relevant provisions from the full SEC Release, now includes the recent FAQs as well as sections from the SEC’s Reply Brief.
Our Interactive Flowchart provides big picture guidance, definitions and examples with accompanying release (and now FAQ and SEC Reply Brief) citations to help you navigate the Conflict Minerals Rule, the Release and the SEC flowchart.