February 14, 2017
77 Fed. Reg. 56,274 (Sept. 12, 2012) (codified at 17 C.F.R. 240, 249b).
Regarding Conflict Metals reporting:
I have read the commissioners statement regarding a two year suspension of the conflict metals rule and strongly support the suspension, and ultimate repeal of the rule. While most commentary on the matter deal with the unintended consequences of the rule in the Congo and other regions meant to be protected by the rule, there are significant unintended consequences to small businesses as well. I am general counsel at a small steel service center in Cincinnati, Ohio. Because we are not a producer of steel or other metals, and we do not add material to our steel, we are not required to report conflict metals usage to the SEC or otherwise comply with reporting and sourcing rules. However, many of our customers who are required to comply, or otherwise choose to, require us to report on conflict metals in our products in order to do business with them. The burden this places on this small business, which never purchases from conflict metal source countries, in order to comply with our customer's obligations under the law, is quite burdensome. As such, I strongly support the suspension and ultimate repeal of the law.
Peggy Barker
General Counsel
Riverfront Steel, Inc.