The Final CY2014 Conflict Minerals Filings Count, and What to Do Now

UPDATE:  Two more issuer filed July 9-10, bringing the total to 1,274 CY2014 filers.  We determined that one filing earlier in 2015 actually covered CY2013, rather than CY2014.

The final CY2014 conflict minerals filing tally was something of a surprise.  Our research indicates the following:

  • 1,274 total CY2014 filers, compared to 1,328 total for CY2013.
  • At least 55 CY2014 filers seem as though they should have filed for CY2013, but did not.
  • 6 total IPSAs were submitted for CY2014, up from 4 last year.
  • 3 IPSAs were conducted by CPAs and 3 by non-CPAs (including Elm), the same ratio as last year.
  • One filing made in 2015 actually covered CY2013 rather than CY2014.  We have excluded this one from our statistics relating to 2015.

Obviously, work continues but the uncertainty of the NAM v. SEC lawsuit weighs more heavily since CY2014 marks the end of the original “DRC Conflict Undeterminable” – and IPSA deferral – window.  What should you be doing/planning now in relation to your CY2015 filing?  We recommend moving forward as the original rule is written – plan to disclose your status as either “DRC Conflict Free” or “not DRC Conflict Free”, and plan on conducting an IPSA if you find material sourced from Covered Countries.  Our opinion is that the legal challenge is likely to be resolved in some way prior to the May 31, 2016 filing deadline and that the resolution will look very similar to the SEC’s original requirement.

We also recommend that you begin in earnest to identify your IPSA auditor and get an early – and formal – schedule commitment.  A severely limited number of qualified/experienced auditors is available and demand will far exceed supply.  We ourselves will be conducting internal training for all Principals to conduct IPSAs on their own, as well as provide strict quality control reviews.  We invite you to review our pricing structure for IPSAs, which has been very well received.  Give us a call or send an email if you would like us to discuss your IPSA.

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