Jenner & Block

Client Alert: SEC Requires Conflict Minerals Filings to be Made by Existing Deadline

On April 29, the SEC announced that it expects companies to meet the existing June 2 deadline for conflict minerals filings with few changes to those filings despite a decision by the D.C. Circuit Court finding a portion of the conflict minerals rules unconstitutional on free speech grounds. The SEC’s key change to the current disclosure requirements as a result of the recent Circuit Court decision is that companies will not be required to publicly label their products as “DRC conflict free,” “not  found to be ‘DRC conflict free’,” or “DRC conflict undeterminable.”