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CEI Submits Supplemental Comments on SEC’s Proposed Conflict Minerals Rules

Regulatory Comments and Testimony

Title

CEI Submits Supplemental Comments on SEC’s Proposed Conflict Minerals Rules

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The Competitive Enterprise Institute has submitted supplemental comments regarding Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, a provision that would require forced supply chain audits and disclosure procedures for public firms that participate in commercial activity involving "conflict minerals."

This comment letter discusses the following points:

  1. Similar forced supply chain audits and disclosures for blood diamonds have failed in the past.
  2. Forced supply chain audits and disclosures will likely increase the violence in the Democratic Republic of the Congo, contrary to the legislation's intent.
  3. Forced supply chain audits and disclosures will impose massive costs on U.S. businesses.
John Berlau & Alex Nowrasteh & Luke Pelican - Supplemental Comments on the Proposed Conflict Minerals Rule