Subject: File No. S7-40-10
From: Carol Lawson

January 15, 2011

Dear Chairman Schapiro and Commissioners,

You handed us the fiasco of non-regulation that led to the economic meltdown and bank failures by failure to police securities and now you have an opportunity  take action that would be a true public relations coup -- but its always business as usual with a nod and wink and hoping no one notices.  You let the American people down.  Get real about something other than your large paycheck.

 I’m writing you with deep disappointment and concern. I understand that the final rule for Section 1502 (conflict minerals) has been delayed once again and is yet to be released. I’m calling on you to release a strong, final rule as soon as possible, and no later than the end of January. I also call on you to ensure that there are no additional delays or phase-in periods built into the rule itself.

The rules for implementation of Section 1502 were to be completed within 270 days of the signing of Dodd-Frank Act, or April 2011. As we enter the New Year over 530 days have passed, nearly double the allotted time.

Significant steps are being taken to ensure conflict minerals no longer line the pockets of armed groups in large part due to the passage of Section 1502, but the delay of the SEC rulemaking is a threat to this progress.

For investors, who have already stated that this is of material concern to them, delays in issuance of the rules limits their ability to have access to critical information regarding companies’ management of risk in their global supply chains.

Most importantly, for the Congolese people, further delays mean armed groups can continue to prey upon and draw financing from the minerals sector, while fuelling instability and committing human rights abuses against civilian populations.

This is why I am urging you to release a strong, final rule no later than the end of January 2012 with no additional phase-in periods or delays included in the rule.

It has been nearly a year and a half since President Obama signed the law; it is time to put this law to action.

Sincerely,

Carol Lawson