With the Securities and Exchange Commission likely to vote on three highly anticipated rules on Wednesday, a last-minute pitch is underway to influence those deliberations.

At an open meeting on Aug. 22 the Commission will consider whether to adopt rules regarding disclosure and reporting obligations with respect to the use of conflict minerals. It will also consider adopting rules regarding disclosure and reporting obligations for payments to governments that are made by resource extraction companies. Both rules stem from mandates included in the Dodd-Frank Act.

The Commission has taken heat from both legislators and activist groups, including a lawsuit filed by Oxfam America, over what have been called unreasonable delays.

On the conflict minerals rule, the Congressional Steel Caucus, a bipartisan group of 100 legislators who represent districts with steel manufacturers, has urged—no surprise—that steel be excluded.

In a letter to SEC Chairman Mary Schapiro, U.S. Rep. Tim Murphy, a Republican from Pennsylvania, and Indiana Democrat Peter Visclosky wrote that: “Unless scrap steel is specifically exempted as a conflict mineral, the rule will put U.S. steelmakers at a severe competitive disadvantage globally.”

They wrote of the “inherent impossibility of tracking and tracing the conflict minerals in scrap steel” because conflict minerals contained in the scrap, such as tantalum and tungsten, may “have been mined years or decades the past, or numerous times over.”

On the undercard of the meeting, before the conflict minerals vote, is a proposal to eliminate the ban against general solicitation and advertising for securities offerings pursuant to Rule 506 of Regulation D under the Securities Act. That change, set in motion with the passage of the JOBS Act, would eliminate the decades-old requirement that securities offerings could only be made to parties having a pre-existing relationship with the issuer. Under the new rule, as long as purchasers are accredited investors, and the issuer takes reasonable steps to either assure that status or otherwise provide required disclosures, products can be broadly marketed, potentially through websites, e-mail and print media.

Among the letters received this week by the SEC was one from Jack Herstein, president of the North American Securities Administrators Association (NASAA), an association of state securities regulators. He weighed in on the Rule 506 amendment, expressing concern is that the Commission might choose to adopt an interim rule, while simultaneously soliciting comment on a proposed final rule.

He urged the commission to “follow its normal course of publishing the proposed rule for public comment before it becomes effective.”

“We realize the JOBS Act contains a 90-day limit for the changes to Rule 506, but we note that many of the rulemakings required by the Dodd-Frank Act are long overdue,” Herstein wrote. “We encourage the Commission to prioritize investor-protection rules ahead of the exemptions in the JOBS Act, and we urge you to resist the pressure to act hastily, especially where ill-considered changes could have such devastating impacts on investors.”

Herstein also urged the Commission to make good on its obligation to conduct a cost-benefit analysis and “apply the same standards to an exemptive rulemaking that it applies to other rules that are less popular.” That evaluation should include losses sustained in low-quality investments that are marketable under the newly-expanded Rule 506, but “would never have been sold successfully in a registered offering that required full disclosure,” he wrote. According to NASAA, in 2011 states brought more than 200 enforcement actions for fraudulent Rule 506 offerings.

Offering a similar view, that agreeing to an interim rule would be a “risky practice,” was a letter delivered to the SEC on Aug. 15 from consumer advocacy groups (among them the Consumer Federation of America and Americans for Financial Reform) and former SEC officials.

They wrote that “the political pressure that has been placed on the Commission to rush to adopt this and other JOBS Act rules,” would make it difficult, if not impossible, to backpedal once comments are received. The letter adds that “it would simply not be possible for the Commission to adequately consider by August 22 the … very real risk of an upsurge in abusive private equity and hedge fund advertising and marketing practices based on misleading performance claims.”

Those concerns were apparently shared by SEC Chairman Mary Schapiro who on Monday, through a spokesman, announced that the Commission would take the interim rule option off the table and instead provide a traditional public comment period in advance of a final rule.