On January 20th, 2009 the Canadian Security Administrators (CSA) announced a project to review and revise National
Instrument 43-101 that governs the disclosure for Mineral Projects in Canada. Below is the submission that Corebox made
to the review committee.
Subject: NI 43-101 Standards of Disclosure for Mineral Projects
From: Jonathan Longe <XXXXXXXXXX@corebox.net>
Date: Wed, 29 Apr 2009 09:43:04 -0700
CSA NI 43-101 Review Committee,
Corebox.net is a provider of interactive analytical tools which help
investors understand drill results. Our displays, which are available
free of charge to the public on our website are graphical representations
of drill results disclosed by mining companies in news releases or otherwise.
We welcome the opportunity to offer suggestions on how to improve National
Instrument 43-101; the following are our comments:
Section 3.3(2)(c) of National Instrument 43-101 currently requires mining
company issuers to disclose the location of samples when results are released
but, in our view, such information is often not adequately disclosed or not
disclosed at all.
We believe the 43-101 could be improved by clarifying how companies should
meet their obligations with respect to disclosing the spatial relationship
of drill intercepts.
At present, when companies provide a map or cross section, it’s often used
to illustrate the best cross section or the location of the best intercepts
and not a complete picture of all drill results.
It would be onerous to require companies to prepare a drill plan and complete
set of cross sections every time results are released. We therefore submit
that the existing provisions of NI 43-101 should be modified so that issuers
are required, at least, to state drill collar coordinates (easting, northing
and elevation) along with azimuth, dip and total depth (and downhole survey
data, if available) for any drill results provided in written disclosure.
The release of such data requires less time and effort than preparing maps
and diagrams that illustrate the same. In addition, it’s much easier for
regulators to verify that collar data has been disclosed than judge whether
a series of images or diagrams include all relevant information and is of a
sufficient scale to meet disclosure requirements.
To avoid making news releases lengthier and more difficult to read, we suggest
that issuers be encouraged to disclose the data by reference to a web site.
As an alternative to a revision of NI 43-101, Corebox.net would also support
a modification to the companion policy with the above requirements added.
We believe these revisions, if adopted, would neither increase nor decrease
the regulatory burden of companies. The 43-101, as currently drafted,
already requires the disclosure of sample locations. Companies routinely
survey the location of the drill collars and the direction the hole was
drilled. It takes minimal work to place this data on a web site.
The attached petition, signed by a number of influential mining analysts
and fund managers, provides evidence of broad support for this revision.
[Editor's note: to protect the privacy of the signatories, the petition
is not shown here.]
If you wish to discuss these suggestions please feel free to contact the
undersigned at (604) 879-9776.
Corebox Online Services Inc.
-- Jonathan Longe | Corebox.net 300 - 1055 West Hastings St. | Vancouver BC V6E 2E9 | CANADA P: 604-879-9776 | F: 604-628-5246 http://www.corebox.net