January 7, 2015

Conflict Minerals: EDGAR is Fixed for Form SD Exhibits

Hat tip to Hunton & Williams’ Scott Kimpel for reading the latest update to the Edgar Filer Manual, which reveals that the SEC has fixed that bug that caused problems for some issuers that filed Exhibit 1.01 to Form SD. Form 1.01 will be allowed going forward; Exhibit 1.02 will not. Here’s the summary from the SEC:

A new exhibit type EX-1.01 will be available on EDGARLink Online for submission form types SD and SD/A. Filers that are filing a Conflict Minerals Report should specify Item 1.02 on a Form SD or SD/A submission and attach the Conflict Minerals Report as EX-1.01 in official ASCII or HTML format. Exhibit type EX-1.02, which was previously allowed on an SD and SD/A submission, will no longer be available on EDGARLink Online or accepted by EDGAR.

Meanwhile, as noted in this Dodd-Frank blog, during the final week of 2014, appellants National Association of Manufacturers, U.S. Chamber of Commerce and Business Roundtable filed their supplemental brief in the conflict minerals case…

Poll: How Many Pages in the Longest 10-K Filed During 2014?

Take a guess as to how many pages were in the longest Form 10-K filed during 2014 – the page count includes exhibits. I will blog next week with the answer:

free polls

Transfer Agents: More Regulation Coming?

Here’s a topic that you don’t often see tackled by a SEC Commissioner – the regulation of transfer agents. Recently, SEC Commissioner Aguilar delivered this statement (interestingly, not a speech) calling for updating the oversight of transfer agents. It’s in an easy-to-read Q&A format.

– Broc Romanek