Dodd-Frank Conflict Mineral Disclosures Cost $700 Million, New Survey Finds

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By Rob Tricchinelli

Eligible issuers spent more than $700 million to comply with Dodd-Frank's provisions that require disclosure for businesses that use conflict minerals, according to a survey from Tulane University's Payson Center for International Development.

Each of the roughly 1,300 issuers required to file Form SD under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act spent more than $540,000 to comply with the law, the survey found, a figure that included companies' internal time use and external expenditures.

The survey was based on responses from 112 of the 1300 eligible issuers.

Issuers with less than $100 million in annual revenue spent less than $200,000 on average, approximately one-third what large issuers spent, according to the survey.

Change Desired

Almost two-thirds of the companies surveyed said they would like to see some change to Section 1502.

1934 Securities Exchange Act Rule 13p-1 requires U.S. public companies and foreign private issuers to disclose their use of so-called “conflict minerals”—gold, tantalum, tin and tungsten from the Democratic Republic of Congo and surrounding region—if those minerals are “necessary” to a product they made .

The 1,300 issuers filed their first-ever disclosures in June, which covered their use of the minerals in calendar year 2013.

The SEC has not issued an official statement on the filings, and a legal case concerning the constitutionality of the rule is ongoing .

The survey is available at

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