“Conflict Minerals” Provisions in Financial Reform Legislation Impose New Reporting Requirements

On July 21, 2010, President Obama signed into law the “Dodd-Frank Wall Street Reform and Consumer Protection Act”. Virtually unnoticed among the sweeping financial regulatory reforms embodied in the statute were provisions squarely aimed at discouraging the use of “conflict minerals” in the manufacture of a wide array of electronic devices, including laptop computers, smart phones, digital cameras, and gaming consoles. Specifically, as detailed below, the Dodd-Frank Act mandates annual reporting to the U.S. Securities and Exchange Commission regarding the use of such minerals in manufactured goods and the efforts being undertaken by the manufacturer to exercise due diligence on the source and chain of custody of such minerals.