Four Common Mistakes Found In CMRTs

Four Common Mistakes Found In CMRTs

We see a lot of Conflict Minerals Reporting Templates (CMRTs) here at Assent Compliance. Most are completed properly, but we inevitably come across many that are either not filled out completely, contain too little or too much information, or have some other kind of error that makes them unusable.

Incomplete or incorrect CMRTs means more work for everyone, including suppliers. It’s important to do it right the first time, saving everyone time and money trying to fix these mistakes. Here are the four most common errors we find in CMRT submissions to Assent Compliance.

 

1. Using the Wrong CMRT Version

Like with any industry, change is sometimes met with resistance and new forms take time to receive buy-in. This is a problem because, as we all know, the world of compliance is always changing. In the short time companies have been required to report on conflict minerals in their supply chain under the Dodd-Frank Act Section 1502, we are already at version 4.01b of the CMRT. However, some compliance specialists are still using pre-4.0 versions of the template.

Over the various iterations of the template, language has changed to clarify what data the form is trying to collect, along with the form’s actual content. Using the wrong form could mean filers are collecting and reporting incorrect data.

Click here for more information and to download the most recent version of the CMRT.

 

2. Too Much Text & Formatting In the Template

It’s important to be clear and concise when filling out a CMRT, specifically in the comments fields of the Declarations tab and on the Smelter tab.

Keep in mind these templates are being used to track conflict minerals in a supply chain. This means companies are reviewing CMRTs, sometimes by the thousands, for specific information. The more information that gets buried in the comments, the easier it can be to miss the details.

First, prioritize the information that needs to be included in the comments section of the declaration. Then, input that information in the most clear and concise way possible so as to ensure the clarity of the message. Additional formatting is not required.

 

3. Don’t Tamper With the Files

The CMRT is nothing more than a specifically designed excel sheet that requires data to be entered into the blank fields. That’s it.

However, some people try to adjust the formulas or change settings on the CMRT, and this can lead to errors in the file. A CMRT that has been tampered with in this way often cannot be used, either because the template is no longer correct or because a software program is not able to integrate the template into the system.

Stick to the template, as-is. The information should be entered into the blank fields provided.

 

4. Green Means Go, Red Means No

This issue is specific to the Assent Supplier Portal, where the majority of our clients’ CMRTs are submitted.

When a CMRT is submitted through the portal, Assent uses an algorithm to review the template and determine whether or not it is accurate and complete. In terms of accuracy, the template is reviewed to make sure certain fields in the CMRT are not contradicting one another.

This is represented to the filer as a red bar, which means the template is bad, or a green bar, which indicates the template is good.

The benefits of this algorithmic process are obvious: filers get immediate feedback on their CMRT and can file with confidence knowing the template was properly completed and submitted. However, it is important to pay attention to the status bar. If it is red, the filer will receive an automated email telling them the issue found within the CMRT. They must then fix the issue and resubmit the CMRT.

Do not ignore emails from Assent Compliance stating your CMRT is invalid.

 

These are four common but not exclusive problems found within CMRTs. If you have any questions about what should be in your CMRT, or how to file it properly, click here and navigate to ‘Help Videos’ for an instructional video.

For more information on CMRTs or your annual Conflict Minerals Reports, contact info@assentcompliance.com to speak with a regulatory expert.

Newsletter