In an order earlier today, the SEC issued a partial stay of the conflict minerals rule that is consistent with the staff guidance discussed in our Alert Memo dated April 30, 2014, available here. The SEC’s order denied a motion for a full stay filed on April 30, 2014 by the parties who challenged the rule in court. As a practical matter, the Commission’s action does not change how issuers must comply with the rule, as provided in the staff guidance earlier in the week, although the plaintiffs are now able to seek a full stay or other relief from the court.
Please feel free to call any of your regular contacts at the Firm or any of our partners and counsel listed under Capital Markets or Corporate Governance in the Practices section if you have any questions.