Costs of Conflict Minerals Compliance (1 of 3) - Why Lower than Expected?

Jun 30, 2017 | Dynda A. Thomas
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The out-of-pocket costs of compliance with the SEC conflict minerals rule have been lower than those originally estimated by industry and by the SEC. But, it’s not because the original estimates were over-stated or inflated. And, these lower than expected out-of-pocket costs don’t mean that business’ concerns about compliance were misplaced. These lower costs have resulted mostly (but not completely) from tools and approaches developed by industry.

So, borrowing from late night TV, here are (in reverse order) 11 reasons why the out-of-pocket costs of compliance with the SEC conflict minerals rule have been lower than originally estimated:

11. Scoring and benchmarking by only one group. The most significant and visible scoring and benchmarking of conflict minerals disclosure has been done by one group — initially the group was at Tulane University and now that group is known as Development International. Because the scoring and benchmarking is being published by one group, companies have been saved from navigating among various and inconsistent scoring methodologies and results.