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	<title>
	Comments on: Dodd-Frank conflict minerals fiasco, cont&#8217;d	</title>
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		<title>
		By: Chuck Blakeman		</title>
		<link>https://www.overlawyered.com/2014/12/conflict-minerals-fiasco/comment-page-1/#comment-314206</link>

		<dc:creator><![CDATA[Chuck Blakeman]]></dc:creator>
		<pubDate>Wed, 03 Dec 2014 23:11:41 +0000</pubDate>
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					<description><![CDATA[Trevor et al,

Dodd-Frank does not just effect publicly traded companies and &quot;all others in their supply chain.&quot; Even though the law is written to regulate them, the fact is that every company of every size has been driven out of the Congo by the default embargo of all minerals coming out of the nine central African countries. 

This default embargo resulted from every smelter in the world deciding that it wasn&#039;t worth risking taking anything from the Congo that they could get somewhere else without the stigma created by the very wrong-minded Enough Project and other NGOs.

And worse, it has resulted in driving ten million people who were living in poverty fully into utter devastation. I, and many others, were shouting  about this in 2010 before this act of colonialistic arrogance was even implemented - http://chuckb.me/xmF]]></description>
			<content:encoded><![CDATA[<p>Trevor et al,</p>
<p>Dodd-Frank does not just effect publicly traded companies and &#8220;all others in their supply chain.&#8221; Even though the law is written to regulate them, the fact is that every company of every size has been driven out of the Congo by the default embargo of all minerals coming out of the nine central African countries. </p>
<p>This default embargo resulted from every smelter in the world deciding that it wasn&#8217;t worth risking taking anything from the Congo that they could get somewhere else without the stigma created by the very wrong-minded Enough Project and other NGOs.</p>
<p>And worse, it has resulted in driving ten million people who were living in poverty fully into utter devastation. I, and many others, were shouting  about this in 2010 before this act of colonialistic arrogance was even implemented &#8211; <a href="http://chuckb.me/xmF" rel="nofollow ugc">http://chuckb.me/xmF</a></p>
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		<title>
		By: Trevor		</title>
		<link>https://www.overlawyered.com/2014/12/conflict-minerals-fiasco/comment-page-1/#comment-314156</link>

		<dc:creator><![CDATA[Trevor]]></dc:creator>
		<pubDate>Tue, 02 Dec 2014 20:35:56 +0000</pubDate>
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					<description><![CDATA[The writing regarding the impact of Dodd-Frank&#039;s conflict minerals provisions keeps being limited to publicly-traded US companies (technically, those filing reports with the SEC under 13(a) or 15(d) of the Exchange Act). That grossly under-reports the actual impact, even though those are the companies who must file with the SEC.

The actual impact is to publicly-traded companies &lt;b&gt;AND all other companies in their supply chain&lt;/b&gt;. When you include all the companies in the supply chains of publicly-traded companies, you increase the impact many-fold. Even if a publicly-traded company only has a hundred suppliers, those hundred suppliers have a hundred suppliers of their own.

And a company who must file conflict minerals reports with the SEC has to get the conflict minerals data for their filing from their suppliers, who have to get it from THEIR suppliers. And the supply chain may go many levels deep.

Publicly-traded companies are given an impossible task, and then they pass that impossible task down the chain to others, who while they might not be directly obligated under Dodd-Frank to file anything themselves, are nonetheless obligated to get the information upstream or else be cut-off from further sales.]]></description>
			<content:encoded><![CDATA[<p>The writing regarding the impact of Dodd-Frank&#8217;s conflict minerals provisions keeps being limited to publicly-traded US companies (technically, those filing reports with the SEC under 13(a) or 15(d) of the Exchange Act). That grossly under-reports the actual impact, even though those are the companies who must file with the SEC.</p>
<p>The actual impact is to publicly-traded companies <b>AND all other companies in their supply chain</b>. When you include all the companies in the supply chains of publicly-traded companies, you increase the impact many-fold. Even if a publicly-traded company only has a hundred suppliers, those hundred suppliers have a hundred suppliers of their own.</p>
<p>And a company who must file conflict minerals reports with the SEC has to get the conflict minerals data for their filing from their suppliers, who have to get it from THEIR suppliers. And the supply chain may go many levels deep.</p>
<p>Publicly-traded companies are given an impossible task, and then they pass that impossible task down the chain to others, who while they might not be directly obligated under Dodd-Frank to file anything themselves, are nonetheless obligated to get the information upstream or else be cut-off from further sales.</p>
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