43-101 Submission
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
To: NI43-101@bcsc.bc.ca, NI43-101@osc.gov.on.ca
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.
Yours truly,
Jonathan Longe
President
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