On April 9, 2015, the Canadian Securities Administrators (CSA)
issued CSA Staff Notice 43‑309 (Review of Website
Investor Presentations by Mining Issuers), which summarizes
the findings of a review of investor presentations on mining
issuers’ websites. Key findings from the review conducted by
staff of the British Columbia Securities Commission, the Ontario
Securities Commission, and the Autorité des marchés
financiers (collectively, the Principal Mining Jurisdiction),
Naming a qualified person (QP), on technical disclosure
and position with the Issuer
Preliminary economic assessments (PEA), use of inferred
resources and achievement risk
Mineral resources and mineral reserves, “resources
are not reserves”
Exploration targets, conceptual only and basis for ranges
Historic estimates, “not to be relied
The CSA is also concerned with the use of words
such as “world class”, “spectacular”,
“production ready” and “ore”. Some
disclosure, particularly where there is economic analysis, may
trigger a technical report filing to support the economic
The Principal Mining Jurisdiction
reviewed investor presentations from the websites of 130 mining
issuers to determine if they complied with NI 43‑101
(Standards of Disclosure for Mineral Projects), part of
NI 51‑102 (Continuous Disclosure Obligations),
and other securities legislation. In some instances, their reviews
resulted in corrective news releases, technical report filings or
The CSA was also concerned about
reference to quality assurance (QA) and quality control (QC), and
naming a laboratory. Other areas of concern were failure to include
taxes in economic studies, metal price assumptions, drilling
information regarding true widths and higher grade
In addition, forward looking information
often did not provide material factors and assumptions used to
develop such information.
Significant non‑compliance areas
identified by the CSA included: naming the QP, PEA cautionary
language, resources are not reserves, tax implications on economic
studies, exploration targets, historical estimates, resources
including reserves, data verification, naming the laboratory, QA
and QC measures, higher grade intervals in drill intercepts and
true width of drill intercepts.
This is the first in-depth review of
mining issuers’ websites, but the review process will
continue and likely expand to other issuers. It is, therefore,
important that all issuers review their disclosure to ensure it
complies with not only NI 43‑101, but also the forward
looking information under NI 51‑102.
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