The CFFiM supports the Canadian Securities Administrator’s (CSA’s) objective of updating Canada’s disclosure regime for mining issuers.

Within Canada, the mineral industry represents the largest cohort of all public issuers. Mineral exploration, including critical minerals, has therefore been identified as a policy priority for the federal government.

Canadian mining issuers face numerous challenges to their continued competitiveness, which makes them particularly sensitive to overregulation.

Given the geographic distribution of mining issuers across Canada, the absence of a national cost-benefit assessment represents a notable gap in the CSA’s rule-making process.

The CFFiM encourages the CSA to engage with mining issuers to support the broader reforms that may be necessary beyond the Proposed Amendments.

Finally, certain elements of the Proposed Amendments lack sufficient explanation or appear unnecessary based on the information provided in the CSA’s Request for Comment and should be reconsidered.

The CFFiM’s comment letter is found here.