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To: hoov who wrote (2092)7/17/2015 8:20:00 PM
From: stuffbug2 Recommendations

Recommended By
hoov
youngun

  Read Replies (3) | Respond to of 22811
 
Hoov, thanks for the great lesson.
NI 43-101 did not contemplate the requirement to disclose material information of this kind. The material information was not retracted, it was clarified.
This is my understanding of what transpired.

1. Bruce Duncan received information relevant to the highly purified Miller graphite (the pricing letter).
2. CCB deemed the information to be material.
3. As public companies have an obligation to disclose material information, CCB drafted a news release and submitted it to the regulators who gave it their blessing.
4. After the news release was published, the regulators re-thought the situation because NI 43-101 does not have in place have any rules that cover this exact scenario.
5. The regulators subsequently requested that CCB clarify the pricing information contained within the news release and CCB complied with the request.

It certainly appears that the regulators concurred with CCB regarding the materiality of the information and the duty to disclose (otherwise they would have informed CCB that the news release was unnecessary).

The clarification news release contains the following:
To avoid any misinterpretation as to the value of graphite mineralization that may be hosted on the company's mineral property, all future graphite pricing information will be limited to disclosure within the Preliminary Economic Assessment.
Does this mean that indicative pricing letters are not to be considered material information?
Or is this only the case when a reserve estimate has yet to be completed?
Should CCB receive another pricing letter, what, if anything, needs to be disclosed?