Recall that the "conflict minerals" provision of Dodd-Frank requires that public companies that make products using such minerals, which include columbite-tantalite (coltan), cassiterite, gold, wolframite, diamonds and others, must produce documents containing a raft of disclosures. These disclosures include documentation of due diligence efforts and supply chain audits and the like.

The goal was to discourage the use of minerals that might be financing various conflicts in the Democratic Republic of Congo, which have tragically resulted in a gross gender-based violence. Early on, it appeared that electronics and jewelry manufacturers would be the most affected. But it's now clear that the law encompasses many more companies.

According to KMPG, the law has a "direct bearing on reporting requirements" on about one-half (at least 6,000) of all publicly traded U.S. companies. As of now, the SEC has yet to issue the final rules and more delays may be on the way, given the agency's Dodd-Frank workload. However, several corporations and industry groups have already begun efforts to trace conflict materials in their supply chain, given that the timeline for implementation once the rules are finalized could well be tight.

Cfo.com offers a look at how this effort is going. It notes that companies are running into some information roadblocks. Especially for large manufacturers of complex products, the supply chain can be quite nuanced and lots of companies simply do not have the sort of granular information compliance officers are looking for. The stakes are high for CFOs especially, as they have to sign off on the financials. We have to think that the SEC will address these concerns as they read the public comments and formulate final rules.

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Dodd-Frank "conflict minerals" rules spur debate