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Firm Memoranda

SEC Conflict Minerals Guidance: June 2, 2014 Filing Deadline Stands

Date: 05/01/14

On April 29, 2014, the SEC Division of Corporation Finance issued a statement clarifying the effect of  the D.C. Circuit decision in National Association of Manufacturers v. Securities and Exchange Commission, which substantially rejected an effort to invalidate the conflict mineral rules adopted by the SEC, while limiting the disclosure requirement on First Amendment grounds.

CGR Memo - SEC Issues Conflict Minerals Guidance - June 2 2014 Deadline Intact.pdf (pdf | 123.03 KB )