Conflict Minerals: SEC Official Offers Three Pointers on Issuers’ Conflict Mineral Disclosures

Sep 15, 2014 | Yin Wilczek, Bureau of National Affairs
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After staff review of issuers' inaugural conflict mineral disclosures, Keith Higgins, the director of the Securities and Exchange Commission's Division of Corporation Finance, Sept. 12 offered three key observations.

The first is that some issuers conflated their reasonable country-of-origin inquiry (RCOI) with the due diligence requirements, Higgins told the American Bar Association's Business Law Section meeting in Chicago. “Sharpening up the precision” with which issuers describe the RCOI process “would be one observation,” he said.