Following up on Tulane’s seminal cost analysis of the SEC’s 2010 proposed rule on conflict minerals, the University has announced that it is planning a retrospective analysis of the rule’s actual implementation costs. The survey will launch after the first SEC filing deadline and the University hopes to capture actual cost data from those who were obligated to comply with Dodd Frank Section 1502, or perform tasks supporting customers with their compliance.
Chris Bayer, who is leading the study for the University said, “In order to trace whether conflict minerals enter their supply chains, companies around the globe have, since 2011, revisited their company-level policies and procedures, updated or created IT infrastructure, resulting in the dedication of millions of person-hours and the expenditure of billions of dollars. With macro-level data on the modalities, costs, and externalities of compliance with Dodd Frank section 1502, stakeholders in the law-making, law-implementing, and law-abiding sectors may appreciate these aggregated inputs and effects. In June 2014 Tulane University intends to get to the bottom of this matter by launching a representative survey after companies have filed their Form SD.”