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PDAC comments on proposed National Instrument (NI) 51-103 on Ongoing Governance and Disclosure Requirements

The PDAC provided comments to the Canadian Securities Commissions (CSA) on National Instrument 51-103 on Ongoing Governance and Disclosure Requirements for Venture Issuers and amendments to NI 41-101 General Prospectus Requirements NI 44-101 Short Form Prospectus Requirements, NI 45-106 Prospectus and Registration Exemptions and related consequential amendments.  Members of PDAC are not in a position to implement a new disclosure system. Each time new disclosure requirements are imposed, (even if they are intended to reduce the disclosure burden for issuers) there is a significant cost to issuers. Issuers have very recently paid a very high price for the implementation of the new IFRS system, and most are not in position to pay for the implementation of a new annual and interim reporting system.

For more details please see our submission Securities - PDAC Comments - 51-103 Dec 21 2012