Posts Tagged ‘Hogan Lovells’

We are pleased to have as a guest contributor Jeffrey W. Rubin.   Mr. Rubin a partner of Hogan Lovells US LLP practicing in New York, and is the Chair of the Federal Regulation of Securities Committee in the Business Law Section of the American Bar Association.  He can be contacted directly at jeffrey.rubin@hoganlovells.com.  The views he expresses below are solely his own. Certainly one of the most frequently viewed pages on the SEC’s website these past few months has been the page announcing upcoming SEC meetings to adopt rule proposals. Interest in the timing of the SEC’s adoption of its final conflict minerals rules has perhaps prompted most of those views. Although Section 1502 of the Dodd-Frank Act required the SEC to promulgate regulations by last April, that date passed with the SEC caught between the Scylla of a statutory mandate and calls by the Congressional conflict minerals sponsors and NGOs for prompt and strict adoption of the final rules, and the Charybdis of companies’ concerns regarding the extraordinary burdens the rule will impose upon them.  Contrast, for example, the SEC’s estimate that the aggregate additional burden on companies as a result of the rule will be 153,864 hours of

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