May 8, 2017

Political Spending Disclosure: Still Sidelined (But Push Continues)

As noted in this article, the latest version of the omnibus spending bill from Congress would continue to prohibit the SEC from using funds on rulemaking for political contribution disclosure – recent spending bills have also contained this bar.

But that doesn’t mean that others aren’t pushing for more transparency in this area.  The Center for Political Accountability has a new website – – containing a searchable database of information from the 305 S&P 500 companies that post information about some (or all) of their political spending on their corporate websites. While the site’s data includes only spending from each company’s treasury, the “individual company detail” pages link to and, which provide information on PAC & individual contributions at the federal & state level.

Dividends: NYSE Wants Advance Notice of Announcements

This Davis Polk blog says that the NYSE filed a rule proposal with the SEC last month that would require companies to provide at least 10 minutes advance notice of a dividend announcement – not just during the period from 7:00 am until 4:00 pm when the exchange’s immediate release policy is in effect.

Conflict Minerals: GAO Says “Country of Origin” Still a Challenge

Recently, the GAO issued this 16-page annual report on its review of 2015 corporate disclosures under the SEC’s conflict minerals rule. The report says that although companies are more informed about their supply chains, they’re still struggling to identify the country of origin of their conflict minerals. Here’s an excerpt:

As in 2014, a majority of companies reported in 2015 that they were unable to determine the country of origin of the conflict minerals in their products and whether such minerals benefited or financed armed groups in the covered countries. However, companies reported a range of actions they had taken, or planned to take, to build on or improve their due diligence efforts, such as shifting operations or encouraging those in their supply chain to shift from current suppliers to suppliers who are certified as conflict free.

John Jenkins