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.