. FOR AN UPDATE ON SEC’S DELAY OF THE FINAL RULE, CLICK HERE. As veterans of regulatory research, we are accustomed to spending hours poring over a plethora of governmental regulations, background documents, guidance and other reports. Our work with conflict minerals supply chain traceability and SEC’s regulations has been no different. In addition to having completed such audits, we have read and re-read the proposed SEC regulation and its preamble; the OECD Due Diligence Guidance for Responsible Supply Chains of Materials from Conflict-Affected and High Risk Areas, and the Supplement on Tin, Tantalum and Tungsten; the ISO 19011 standard; comments submitted to the SEC on the proposed regulation (approximately 700 total comments were submitted, of which 433 were standard form letters. Of the remaining 270, approximately 75% provide substantive content); hundreds of relevant media reports, legal advisories and NGO documents; various auditor standards under SEC, including Government Accounting Office Government Accounting Standards GAO-07-731G, AICPA Statements on Standards for Attestation Engagements (SSAEs); and industry commentary and alerts on the topic. Yesterday, we completed an analysis of the 263-page report from the Boston Consulting Group (BCG) titled US Securities and Exchange Commission Organizational Study and ReformMarch 10, 2011 to see what
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