Documentation on SEC Position on Tin Available

UPDATE:  This topic was presented in detail by Eric Gotting of Keller and Heckman at last week’s IPC conflict minerals seminar.  As was made clear in their follow up letter to the SEC, the exclusion includes 3TG, not just tin.

The law firm of Keller and Heckman, on behalf of ten industry associations, participated in a telephone conference with  the SEC staff concerning whether non-metallic forms of tin qualify as conflict minerals under the final rule.  The meeting – and its outcome – has been widely publicized, but documented confirmation of the SEC’s position is not expected to be published by SEC themselves.

Earlier this week, however, Keller and Heckman’s follow up letter was published, confirming the Staff’s agreement that non-metallic forms of tin are “chemically distinct from the metal derivatives themselves and thus the agency did not intend the scope of the final rule to reach that far.”

Eric Gotting from Keller and Heckman will be speaking on this at IPC’s Conflict Minerals Conference this Thursday, July 10 in Santa Clara.  Elm will also be presenting.  We hope to see you there.


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