April 13, 2011
April 13, 2011
The Honorable Mary L. Schapiro
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
RE: proposed SEC regulations related to Section 1502 (Conflict Minerals) of the Dodd Frank Act
Dear Chairman Schapiro,
Id like to take this opportunity to comment on proposed SEC regulations related to Section 1502 (Conflict Minerals) of the Dodd Frank Act. My perspective on the Congo conflict minerals provisions are as both a consumer and as a personal investor.
First, as an investor, Ive told my personal financial advisor that I want to informed judgments about socially responsible investments. Specifically, I want to make a choice of whether or not to invest in businesses whose mineral sourcing practices contribute to the on-going crisis in the Democratic Republic of the Congo. I trust the SEC will by implementing the appropriate rules take steps to both reduce investment risks for people like me, and also help to bring an end to the violence in the DRC by allowing me to make choices to avoid investing in companies that source minerals that finance armed groups in that region.
In my role as a citizen and consumer, Im glad Congress has given SEC a mandate to help me choose to purchase goods that I can count on to be truly DRC conflict-free. I realize that some items I might purchase would contain conflict minerals, and I want to avoid that I want to be sure whether the things I buy have contributed to financing the horrific violence in the eastern Congo. It is very important to me to have this choice, and the SEC can assure that I do.
I urge the SEC to require companies to fully comply with all reporting requirements immediately upon release of the final rules. There is no justification for prolonging the suffering of the people in the Congo.
The SEC rule should spell out the details of what companies must do to verify whether they source minerals that benefit armed groups in the Congo. There must be instructions about what companies must do to check their supply chains to find out if they are sourcing conflict minerals that contribute to violence.
In addition, I believe that the rules should require companies labeling products DRC conflict-free to meet a high standard of proof that such labeling is actually true, and both consumers and investors should be able to have easy access to documentation supporting such a claim. To be useful, information reported under the SEC rules must be made easily available both on the SECs website and on the companys website this is very important to my purchasing and investment decisions.
Finally, there should be no exceptions. The rules should cover gold, tin, tungsten and tantalum, and all companies involved with such minerals should be required to provide comprehensive reports.
The work that the SEC is doing is vitally important on this issue, and I appreciate it. Please make every effort to assure that there are strong rules that will properly inform my decision-making abilities as an investor and consumer.
Cullen C Larson
6330 Black Oak Drive
Cumming, GA 30040