In a ruling today, May 14, the Court of Appeals denied the emergency motion to stay the Conflict Minerals Rule. So, companies should complete their analysis and, if necessary, their drafting of Form SDs and Conflict Minerals Reports to be ready to file by the June 2 deadline. However, remember that on May 2, the SEC issued a partial stay of the Conflict Minerals Rule. This partial stay implements the substance of the statement of the Director of Corporation Finance that modified the reporting requirements and was released on Tuesday, April 29th. Our blog post of April 29th summarizes the SEC Statement.
The emergency motion to stay was filed by the National Association of Manufacturers, the US Chamber of Commerce, and the Business Roundtable on May 5.