SEC (U.S. Securities and Exchange Commission)

The U.S. Securities and Exchange Commission (SEC) is the federal regulatory body that administers and enforces the conflict minerals disclosure requirements under Dodd-Frank Section 1502 through Rule 13p-1 and Form SD. The SEC adopted the final Conflict Minerals Rule on August 22, 2012, with reporting beginning for the 2013 calendar year. Form SD filings are submitted to the SEC’s EDGAR system by May 31 annually. In 2025, SEC Commissioner Mark Uyeda publicly questioned the effectiveness and cost burden of the rule, signaling potential policy debate, though the rule remains in force as of April 2026.

SEC Exchange Act Section 13(p); Rule 13p-1; Form SD; SEC Final Rule Release No. 34-67716 (August 22, 2012).

The SEC is the primary enforcement body for U.S. conflict minerals obligations. SEC staff review Form SD submissions via EDGAR and can issue comment letters requesting additional disclosure or clarification. Companies must be prepared to defend their RCOI methodology and due diligence process if questioned. The SEC has historically focused on whether companies are conducting and disclosing due diligence, not on the specific outcomes. The potential for rule revision or enforcement changes under the current administration means companies should monitor SEC announcements closely.

A publicly traded industrial equipment manufacturer files its Form SD via EDGAR on May 29. The SEC reviews the filing and issues a comment letter noting that the company’s RCOI description does not specify how smelter RMAP status was verified. The company responds with supplemental documentation explaining its CMRT review and smelter conformance verification process.