Brian,
In the working group I participate in for this topic (and based on my on read
of the section 1502) there is an effective "loop hole" for companies not
publicly traded. This is perhaps due to the fact that it was put under SEC
jurisdiction and they simply cannot impact non-public companies reporting
(this is, after all, an SEC reporting issue, not a stop requirement).
Your last question is the kicker, and I would add to it..., "how will a big
company be able to trace its stuff to origin if the small component suppliers
{that are not publicly traded in the US} do not have to indicate conformity" +
and US publicly traded *distributors* {who might not be seen as producing
anything} may also be out of scope + and all of the companies between the
mines and the US boarders have no obligation to track or report the data
(other than the contractual pressure that might be exerted by
in-US-publicly-traded-producers)?
You may know that the SEC is collecting public comment on while they work to
develop the detailed regulations for the act. Reference
http://www.sec.gov/spotlight/regreformcomments.shtml
<http://www.sec.gov/spotlight/regreformcomments.shtml>
Regards,
--
Lauren Crane (mr.)
Product Regulatory Analyst | Corporate Product EHS | Applied Materials
Office 512.272.6540 | Mobile 512.736.7201 | America - Europe - Asia
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From: "Brian O'Connell" <[email protected]>
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List-Post: [email protected]
Date: 10/20/2010 07:25 PM
Subject: U.S. conflict-minerals law
Sent by: [email protected]
________________________________
Good People,
YACR (Yet Another Conformity Requirement). A customer has asked if my employer
will be able to make a declaration in accordance with the "Dodd Frank Wall
Street Reform and Consumer Protection Act".
My initial response was that there was no requirement because my employer is
not traded on a major US stock exchange.
Is this an actual 'hole' in the law, or did I not interpret correctly? How
will a big company be able to trace its stuff to origin if the small component
suppliers do not have to indicate conformity ?
Brian
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