October 28, 2011
Tulane Study Says SEC Estimate of Cost of Conflict Mineral Rules is 100x Too Low
Here's a follow-up on yesterday's post concerning the SEC's proposed conflict mineral rules.
The SEC estimated that the cost to implement the new requirements would be just over $70 million. As I indicated yesterday, the SBA's Office of Advocacy disputes the SEC's cost estimates. Now, a study out of Tulane University claims that the actual cost will be $7.93 billion, more than 100 times the SEC's estimate. The study is available here. I haven't reviewed the Tulane study carefully but, as I said yesterday, none of this bodes well for the SEC if it adopts the rule and it is challenged in the D.C. Circuit.