MNP Comment Letter - Proposed Amendments to NI 51-102, NI 41-101 and NI 52-110 Request for Comment

MNP Comment Letter - Proposed Amendments to NI 51-102, NI 41-101 and NI 52-110 Request for Comment


Thank you for the opportunity to comment on the proposed amendments to NI 51-102. We agree with several of the proposed amendments, and with the concept of relieving some of the documentation and regulatory burden placed upon venture issuers. We have reviewed the request for comments and provided below our responses to selected questions.

Conceptually, we agree with the idea of reduced disclosure requirements – the quarterly highlights – for those venture issuers who have yet to generate significant revenue. However, we believe that a definition of “significant revenue”, and detailed application instruction, is needed in order to improve understanding and consistency of implementation amongst venture issuers. Further, as the annual MD&A requirements are not being changed under the proposal, we would expect many venture issuers would simply roll forward the annual MD&A disclosures, rather than investing time to revise and revamp the MD&A to provide only quarterly highlights. As a result, we anticipate that ongoing cost savings as a result of this proposed change will be minimal; in fact, on initial implementation, we would expect costs to increase as venture issuers would likely face professional fees from their legal counsel and/or financial consultants in the review of the first quarterly highlights report.

MNP Comment Letter - Proposed Amendments to NI 51-102, NI 41-101 and NI 52-110 Request for Comment

Contact a member of MNP's Financial Reporting Team

Michelle Balmer

Michelle Balmer CPA, CA

Vice President, Assurance

Michelle Balmer, CPA, CA, is a Senior Assurance Services Partner with MNP. With 14 years of experience in public practice, Michelle helps a broad range of public and privately held companies in a variety of industries. She also works on special projects, including costing studies, benchmarking and best-practice studies, operational analyses, litigation support and due diligence.

As a key member of MNP's Assurance team, Michelle has played an instrumental role in assurance policy development, implementing accounting and assurance standards firm-wide and educating assurance practitioners regarding methodologies and new pronouncements. She also provides technical advice and consultation on accounting and assurance issues, as well as on rules of professional conduct issues, to all MNP practitioners.

Michelle was certified a Chartered Accountant (CA) after obtaining a Bachelor of Commerce degree from the University of Alberta. She has been actively involved with the Institute of Chartered Accountants of Alberta, including the Chartered Accountants School of Business, in an instructional and marketing capacity. An avid volunteer, she has assisted numerous groups such as the Easter Seals of Alberta, Paralympic Sports Association and Junior Achievement of Northern Alberta.