November 25, 2014
Titled “Rehearing Order Shouldn't Disrupt Work on Next Conflict Minerals Filings,” the Nov. 18, 2014, Bloomberg BNA article refers to the U.S. Court of Appeals’ decision to rehear its conflict minerals ruling. Essentially, Rakesh Gopalan and other attorneys agree that public companies should continue their compliance efforts since even a reversal of the ruling would be unlikely to dramatically change the core requirements. In quoted material, Rakesh adds that the required disclosures could be modified or even eliminated if the court took action before the June 1 filing deadline. He also recommends that issuers’ disclosure teams collaborate to ensure consistency in reporting and that issuers be mindful of continuity and succession planning for their conflict minerals reporting to ensure that a sufficient number of staff members understand their companies’ conflict minerals work.