Petitioners Consent Motion to Expedite Review of SEC Adopted Rule 13p-1 and Form SD, Conflict Minerals, 77 Fed. Reg. 56,27On August 22, 2012, the SEC adopted Rule 13p-1 and Form SD, Conflict Minerals, 77 Fed. Reg 56,274 (Sept 12, 2012), which is one of the costliest rules ever issued by the SEC. Promulgated pursuant to Section 1502 of the Dodd-Frank Act, 15 U.S.C. § 78m(p), the Rule requires companies to determine whether any  quantity of tin, tantalum, tungsten, gold or their related ores— even tiny “trace” amounts—are “necessary to the functionality or production” of a product that they manufacture or “contract to manufacture.” 77 Fed. Reg. at 56, 279, 56,297. Companies must then conduct a “reasonable country of origin inquiry” to determine whether there is “reason to believe” that any minerals “may have originated” in the Democratic Republic of the Congo (“DRC”) or at one of the nine adjoining countries (comprising most of central Africa).

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