For those keeping track, we are two weeks away from the SEC conflict minerals disclosure filing deadline and here is where things stand:
- The SEC has not issued any further guidance or statements on the disclosure, the rule or Acting Chair Piwowar’s suspension of enforcement.
- Newly sworn-in permanent Chair Jay Clayton has not given any public indication about his views or possible actions on the disclosure, the rule or Acting Chair Piwowar’s suspension of enforcement.
- We are not aware of any action related to Senator Elizabeth Warren’s request for an investigation into the Acting Chair’s authority to issue the enforcement suspension.
- 60 filings have been submitted – 22 conflict minerals reports and 38 SD-only
- We continue to see variability in issuers including smelter/refiner lists and countries of origin. In addition, implausible countries of origin continue to be listed as well – France being the most common.
- Two IPSAs have been filed, both conducted by the same non-CPA firm. Elm completed two additional IPSAs not yet filed and we expect a handful of other IPSAs when all is said and done.