CIRI Issues Advocacy: CIRI Submission to BCSC on Proposed National Instrument 51-519 - Promotional Activity Disclosure Requirements
CIRI submitted comments to the British Columbia Securities Commission (BCSC) on Proposed National Instrument 51-519 - Promotional Activity Disclosure Requirements, recognizing that recent online events coupled with increased use of social media has led to problematic promotional activity; however, the approach proposed needs refinement.
We recommend that:
'Investor relations activity’ not be included in the definition of ‘promotional activity’;
Consideration be given to the crucial role investor relations consultants play for venture issuers;
The Proposed Instrument and the Companion Policy be amended to narrow the scope and clarify what would and would not constitute promotional activity;
Consideration be given to the point of dissemination as a means to clarify what constitutes promotional activity; and
The Proposed Instrument apply to venture issuers only.
To read the full submission, click here.