UPDATE: Acting SEC Chairman Piwowar issued a statement on January 31, 2017 opening the rule and the 2014 Guidance to public comment.
It has been an unusual campaign and election for the US presidency. Donald Trump will take office in January and the Republicans will control of both houses of the legislature.
So is the fate of the US conflict minerals disclosure mandate in jeopardy? Perhaps, but in our opinion the Trump administration will not change anything before the May 31, 2017 filing deadline for the CY2016 disclosure. We recommend that all companies subject to the conflict minerals filing continue to move forward as planned. Looking even further out, we expect that the administration will face other dragons to slay through 2018 as well. This is expected to be a topic of many conversations at the CFSI workshop we are attending this week.
Trump has made clear his disapproval of the Dodd-Frank Act in toto, so there is a general expectation that change will come, yet he faces other higher priority matters such as healthcare and the Federal budget. But with the Senate and House now controlled by the Republicans, there likely will not be much opposition to a repeal of, or amendments to, Dodd-Frank.
Emerging regulatory initiatives such as expanding SEC reporting to include sustainability matters is also likely to face far more opposition during the Trump administration.
We occasionally are asked what we would do if the conflict minerals mandate was eliminated. We would see some business loss, but Elm Sustainability Partners and The Elm Consulting Group International do much more than conflict minerals advisory.
Elm Sustainability provides a range of sustainability, corporate responsibility and supplier auditing services. We review existing social auditor results and qualifications and are known for calculating economic value of sustainability programs using methods that withstand tough management scrutiny.
The Elm Consulting Group International has been in business for 15 years providing clients with the highest quality environmental, health and safety auditing available and that business continues to grow.
Through our six years in the conflict minerals space, we have made many friends and new clients we hope to continue to serve, whether related to conflict minerals or otherwise. If you are looking for sustainability, social auditing or EHS auditing support, please give us a call.