Conflict Minerals - Comment Letter - Ford Motor Company - March 2, 2011

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Dodd-Frank Timeline, Conflict Minerals, SEC
Final Rule Issue Effective Date First Report Due
September 12, 2012 November 13, 2012 May 31, 2014

Conflict Minerals
March 2, 2011

In the comment letter, Ford requests (among other things) that:

  • "the Staff require the annual disclosure regarding Conflict Minerals to be included in a separate form to be submitted to the Staff within a defined period after the end of a registrant's fiscal year;
  • [the Staff allow] registrants to become accustomed to preparing Conflict Minerals Reports before evaluating whether mandatory 'block' or 'detailed' XBRL tagging would enhance the usefulness of these new disclosures;
  • the Conflict Minerals Report should contain a statement from the registrant that the registrant has obtained an independent third-party audit as required by statute; and
  • registrants 'furnish' rather than 'file' the Conflict Minerals Report, which the Staff asserts, and we agree, contains information qualitatively different from the financial information required to be disclosed in registrants' periodic reporting."


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