By: Kelly Richardson, Buck Endemann and Achraf Farraj

On August 22, 2012, the Securities and Exchange Commission (the SEC) adopted a final rule implementing the conflict minerals provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).[1]  The final rule and its adopting release clarify several issues raised by the SEC’s proposed rule, published in the Federal Register on December 23, 2010.  Significantly, the final rule differs from the proposed rule in one key