On November 30, the Conflict Free Sourcing Initiative, CFSI, released the newest version (v. 4.20) of the Conflict Minerals Reporting Template, CMRT. This is the 15th new release, the sixth release at version 4, and the first update since CMRT v.4.10, released on April 29, 2016.
Updates to CMRT v.4.20 include corrections to bugs and errors, updated smelter lists, IPC 1755 compatible enhancements to the instructions page and an update to ISO short names for countries, and finally translational improvements for all updated instructions and definitions.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for April 2017.
The new CMRT provides a unique opportunity for corporations and individuals collecting CMRT data as part of their due diligence surrounding a reasonable country of origin inquiry (RCOI) for SEC Reporting. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 4.20).
Corporations and individuals may use the new CMRT as a mechanism for gathering updated conflict minerals data and improving overall data collection from their suppliers. Alerting suppliers to the new CMRT may lead to a discussion that sets expectations for routine updates and the use of the latest CMRT version. Exclusive use of the new CMRT will produce Form SD filings with the SEC that will show data received in the current year after November 30, 2016. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating a requirement and expectations to a supplier can be similarly used in the Form SD.
