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Message: Of the CSA's NI 43-101 and the SEC's Industry Guide 7

I'm reading a lot of misinformation about the applicability of the NI 43-101 report with regards to SFMI.

NI 43-101 is the reporting requirement for Canadian-listed companies engaged in mining exporation or extraction governing on how companies may disclose or classify its resources. It has no applicability to non-Canadian listed companies as those companies must adhere to the reporting requirements of those registrant's jurisdiction. In SFMI's case, they are a US-based, SEC-reporting company, and as such, they are bound by the terms of the SEC's Industry Guide 7, not Canada's NI 43-101.

https://www.sec.gov/about/forms/industryguides.pdf

The only time an SEC-filing company should be referencing anything related to NI 43-101 is if they are dual-listed or if they've acquired a mining company that was listed on the Canadian exchange. Otherwise, the SEC forbids companies from disclosing or using particular terms (proven or probable reserves) with regards to mineralization, grade and tonnage unless they are following the instructions set out under Industry Guide 7. Industry Guide 7 is unfortunately a more daunting level of disclosure than NI 43-101 in that the SEC requires a bankable feasibility study to be performed before allowing such disclosures by companies.

"Proven and probable reserves are achieved by obtaining an engineering and economic feasibility study and economic valuation determination that meet the technical requirements to support a resource or reserve under Guide 7, and the SEC has requested that companies remove disclosure relating to large tonnage, low grade resources that do not meet the technical requirements to support a resource or reserve under Guide 7"

http://www.wfw.com/Publications/Publication1150/$File/PLC-PublicMiningCompanyDisclosure-Nov12.pdf

So what this means to SFMI is that they are either uninformed about their company's reporting requirements as an SEC filer or they are misleading investors. Given that Industry Guide 7 is much more arduous in its requirements, particularly requiring an expensive bankable feasibility study (which relies on a certain degree of drilling and exploration), such a geological report that would be acceptable under US Industry Guide 7 standards, would be quite a long ways off for SFMI...that is, if they intend on doing things properly according to the SEC.

What Spiny posted earlier about NI 43-101 is correct about its intent and purpose...IF he were discussing a Canadian-listed company. However, an NI 43-101 has no applicability to a US based SEC filer unless that company is dual-listed.

Why is the company referring to an NI 43-101 when they are not a Canadian listed company? I don't know. That is for each shareholder to decide. You don't have to take my word for it. A shareholder wishing to further their education on the company's plans should perform the due diligence themself. I've only provided a couple of links, but there are hundreds of links discussing this topic that paint the picture that I've described above.

You don't have to agree with my outlook on the company. However, I think it would be prudent as a shareholder in any mining company to know the company's reporting requirements, whether they are doing things by the book, and how that may affect your investment.

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