February 3, 2017
Dear Chairman Piwowar,
Thank you for your solicitation for public comment on the Conflict Minerals rule. I am responsible for the implementation of this rule for my employer. While I appreciate the social intent of this rule, I am frustrated by its unintended consequences of placing undo burden on American manufacturing. My employer, a small to mid sized electronics company, spends over $50,000 per year on consulting fees to comply with this regulation. In addition, I have had to dedicate one of my engineers for several hours per month, along with my own time, administering this requirement. These are hours and funds that limit my teams ability to deliver new products, and new jobs.
I question the global effectiveness of this regulation. Has the SEC considered the social impact of job losses in the US? Has the SEC considered the competitive disadvantage created by this regulation? Has the SEC considered the opportunity cost associated with the need to divert engineering resources to compliance activities? What new technologies and products have been delayed or canceled due to lack of resources caused, in part, by this regulation?It appears such considerations have fallen to the political agendas of those who don't value work who don't value progress.
My involvement and cost may seem small, but if you multiply my experience by the thousands of similar business, you gain a sense of the negative impact of this regulation.
I respectfully request the SEC cease enforcement of conflict minerals rules, in all respects, announcing such a decision as soon as possible.