Dodd-Frank Section 1502 – Filing Evaluation RY2016
Publisher: Development International
Author(s): Chris N. Bayer and Jesse H. Hudson
Date: 2017
Topics: Extractive Resources, Governance
Countries: Congo (DRC)
Reporting year (RY) 2016 represents the fourth year issuers submitted their conflict mineral disclosure (CMD) to the U.S. Securities and Exchange Commission (SEC) pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. As of July 10, 2017, 1,153 issuers filed a CMD describing their due diligence on conflict minerals in their supply chains. We note an overall 5.6% drop in companies filing a conflict minerals disclosure vis-à-vis reporting year 2015. This percentage is slightly higher than prior years, which saw an average filing decrease of 4%. One hundred and twenty-five (125) issuers did not file a RY2016 Conflict Mineral Report (CMR), which had done so for the previous year. Thirty (30) of these 125 former CMR filers did submit a Form SD, whereas 95 did not file anything for RY2016. Yet the great majority of companies continued to file according to their existing compliance obligations.