On January 24, 2013, the BC Securities Commission issued a report (the “2012 Mining Report”) with respect to disclosure and interpretive issues under National Instrument 43 101, which is referenced as “the Mining Rule” in the report. Any questions or comments on the 2012 Mining Report can be submitted to Robert Holland or Ian McCartney of the B.C.S.C.
The report identifies a number of weaknesses in the disclosure of mining companies and provides a useful checklist for compliance measures in Appendix “A” which you can download by clicking ”Download PDF”, and a summary of the mining technical reviews disclosing the common compliance elves on the different disclosures which is also attached to this memo.
The report identifies the following common deficiencies encountered in reviewing technical reports including:
- Missing or altered statements in certificates and consents of the Qualified Persons;
- Not dated, signed, or addressed to the company;
- Non compliant disclaimers of responsibility or statements of reliance;
- Does not provide a summary of all material technical and scientific information for the entire property;
- Non compliant disclosure of historical estimates, exploration targets, or MRMR;
- Does not provide adequate or sufficiently transparent information on the key assumptions, parameters, and methodologies used in mineral resource estimates.
In addition, the report also references the CIM December 15, 2009 publication “Additional Guidance – Reasonable Prospects for Economic Extraction”.
The CIM statement emphasizes that the use of the words “reasonable prospects for economic extraction” in addressing mineral resources are:
- the responsibility of the Qualified Person;
- judgment based on the Qualified Person’s experience; and
- the methods used and assumptions made to determine if the project has “reasonable prospects” which must be presented explicitly in both public and technical reports.
Note that this clarification applies not only to measured and indicated resources, but also inferred reso 2012 Mining Report British Columbia Securities Commission urces and a copy is attached to this memo for reference.
To read Appendix A, click here.