Key takeaways

• On April 29, 2014, the SEC’s Division of Corporation Finance announced that it expects issuers to file on or before June 2, 2014 any reports mandated by the conflict minerals rule as adopted with only limited modifications.
• These modifications are intended to address the recent decision issued by the U.S. Court of Appeals for the District of Columbia finding that certain provisions of the conflict minerals rule and related statute violate the First Amendment to the extent they require issuers to disclose to the SEC or report on their website that any of their products have “not been found to be ‘DRC Conflict free.’”