The Inevitable Failure of Dodd Frank 1502

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) requires all U.S. publicly traded companies to report sourcing details about conflict minerals in their supply chains to the SEC, if and when they source minerals from eastern Democratic Republic of the Congo (DRC) or neighboring countries. The underlying purpose was to cut off the flow of funds to violent actors in the region.  The unintended consequence was that many U.S. companies chose to stop sourcing from the region, due to the difficulty in meeting these requirements.  But this consequence was not unanticipated, and we began to see the fallout during the last week.

So what happened? Yesterday I began to see a slew of tweets indicating some major disclosures about Dodd-Frank's conflict mineral section were coming soon.  It started with this tweet:

Wednesday set to be a humdinger of a news day on DRC conflict minerals. Brace yourselves.
— Laura Seay (@texasinafrica) September 9, 2014

So I started digging and found these tweets:

#DRC: #US government acknowledges it 'cannot determine' cleanliness of supply chains despite Dodd Frank Act - http://t.co/ztqAA5c8Fv 1/4
— christoph vogel (@ethuin) September 9, 2014

#DRC: At the same time, industry claims they spent millions on determining 'conflict-free' minerals while local reality remains dire. 2/4
— christoph vogel (@ethuin) September 9, 2014