The Payson Center for International Development of Tulane University Law School released a study analyzing the results of a June 2014 survey of issuers who filed the required Form SD. The study investigates the market impact of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which applies public disclosure law to Tin, Tantalum, Tungsten and Gold (3TG) – so-called conflict minerals.
The study’s findings reveal that issuers mobilized substantial in-house and external resources, an aggregate total of $709.7 million, to set up conflict mineral programs in order to furnish the required information by June 2, 2014, as per the disclosure law and rule. Issuers each invested an average of $545,962 worth of time and effort to comply with the law, the value of each company’s conflict mineral program largely comprised of in-house corporate time, external human resources, an IT evaluation and IT system expenses. Small issuers, with less than $100 million in revenue, spent $190,330 worth of resources on average – roughly 1/3rd as much as their large issuer counterparts.
With 112 issuers participating in the study, Tulane believes the data is representative of the 1,300 issuers who filed the required Form SD with the SEC.