As of 8:00am eastern time today, 113 Form SDs have been filed since January 1, 2015 covering reporting year 2014. This is far more than had been filed last year four days before the deadline.
More interesting, however, is that 10% of the 113 did not submit a Form SD last year at all. We didn’t look deeper to try to determine why this is the case. A few of our clients have gone through IPOs, sales and divestitures in the 2012 – 2014 time period, which changed their reporting status. Even further, some companies only recently brought to market products that trigger conflict minerals reporting. We are certain that many other filers have gone through similar legitimate changes. But we also expect there to be some companies who missed last year’s filing altogether for other reasons and this will be their first Form SD.