The immediate impact of the court’s order is that the Rule’s June 2, 2014, reporting deadline remains in effect for covered issuers; however, pursuant to the SEC’s May 2, 2014, order partially staying its Conflict Minerals Rule, covered companies are not required to state “DRC conflict free”, “DRC Conflict Undeterminable” or “have not been found to be ‘DRC Conflict Free’” with respect to their covered products. Additionally, unless a covered company elects to describe its products as “DRC Conflict Free”, an independent private sector audit is no longer required.
Our attorneys are available and prepared to assist covered issuers in complying with the fast approaching reporting deadline. We continue to monitor events closely and will provide additional updates as they become available, but do not anticipate any significant developments prior to June 2.