RMI FAQ: New CMRT releases in April generally do not require re-surveying suppliers for the upcoming filing

RMI guidance clarifies supplier-survey timing when a new CMRT is released in April. Companies generally do not need to re-survey suppliers solely due to an April CMRT release for the upcoming filing cycle. Instead, companies should use the latest CMRT version available when initiating their annual survey and clearly state which CMRT version was used/allowed. This impacts annual CMRT data-collection planning, supplier communications, and documentation practices for SEC Form SD / downstream conflict minerals due diligence programs relying on CMRT submissions.