Posts Tagged ‘Foley Hoag’

As is generally known, the corporate disclosure and auditing requirements of Dodd-Frank Section 1502 are to start “with the [company’s] first full fiscal year that begins after the date of promulgation of such regulations.”  Therefore, the timing is a function of both the corporate fiscal year as well as the date of promulgation.  In the wake of SEC moving the window for promulgation of the final conflict minerals rule to between January – June 2012 (with many sources indicating the end of January), we asked several notable legal experts to offer their thoughts on how (or if) this delay would impact publicly traded companies that operate on a fiscal year other than the calendar year. If the rule is indeed promulgated in January, how might a company with a March – February or July – June fiscal year be impacted for 2012?  Would it be plausible to satisfy the CMR reporting requirement with a short summary report on due diligence process development/implementation status that will likely be lacking in significant detail?   _________________________ K. Russell LaMotte is a Principal at Beveridge & Diamond, PC in Washington DC.  He previously served as a senior lawyer at the State Department.  His practice focuses

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