RE: euz interview8 Oct 2021 07:12
Thanks Highside. Found what I was looking for.
What are the main differences between the SEC’s initial proposal in 2016 and the new rules?
The SEC first proposed an overhaul of the disclosure requirements for mining companies, and solicited comments on its proposed rules, in 2016. Many industry organizations, companies, and law firms that commented on the proposals were supportive of the idea of modernization, but felt that the SEC’s proposals were too prescriptive and varied in too many ways from CRIRSCO standards, thereby imposing an administrative burden on companies, especially those reporting in more than one jurisdiction.
In response to these comments, the SEC’s final rules incorporated a number of changes, many of which were intended to more closely align the SEC’s mineral property disclosure requirements with CRIRSCO standards, and thereby help decrease the compliance burden and costs on registrants that are subject to additional CRIRSCO-based codes. For example, as compared to the 2016 proposals, the final rules:
eliminate the prohibition on estimating mineral resources and mineral reserves using a commodity price that is greater than the 24-month historical average;
allow mineral reserves to be declared based on a pre-feasibility study, even in high-risk situations;
allow mineral reserves to include diluting materials and allowances for losses;
permit inferred mineral resources to be included in the economic analysis that is included in an initial assessment (the equivalent to a preliminary economic assessment under Canada’s NI 43-101);
eliminate the requirement for a technical report summary in order to disclose material exploration results;
permit mineral resources and reserves to be disclosed at any specific point of reference selected by the qualified person, rather than three (in situ, plant or mill feed, and saleable product);
permit the use of non-compliant, historic estimates of mineral resources or mineral reserves in SEC filings pertaining to mergers, acquisitions and business combinations, subject to certain conditions;
permit registrants holding royalty or similar interests to omit information to which they lack access and which they cannot obtain without incurring an unreasonable burden or expense;
will not apply to geothermal fields;
permit the disclosure of exploration targets;
eliminate many of the quantitative thresholds in the proposed rules, in favor of more qualitative standards;
reduce the number of required tables, and the amount of information required to be included in tables;
clarify that technical report summaries may be authored by more than one qualified person; and
allow a qualified person to rely on certain information provided by the registrant.
In addition, the final rules clarify that when a qualified person is not an employee of the registrant and is not otherwise affiliated with the registrant, the technical report summary and any required expert consent may be signed by ….tbc
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