On December 30, 2011, the SEC updated its Dodd-Frank implementation schedule to reflect that it plans to adopt final rules under Section 1502 of the Dodd-Frank Act, the conflict minerals provision, sometime between January and June 2012, instead of by the end of 2011 as previously planned.

Under Section 1502 and the SEC's proposed conflict minerals rules, covered companies must make conflict minerals disclosure beginning with their first full fiscal year that starts after the SEC adopts final rules. Therefore, this postponement changes the expected date that calendar-year companies must begin conflict minerals due diligence and disclosure under Section 1502. If final rules are adopted as proposed according to the new plan, calendar-year companies would need to make disclosure starting with their annual report for 2013 (due in 2014).

For more information on Section 1502 and the proposed conflict minerals rules, see Practice Note, Conflict Minerals Due Diligence and Conflict Minerals Disclosure Requirements Checklist.