CSA Staff Notice: 51-308 - Filing of Management's Discussion and Analysis and National Instrument 51-102 - Continuous Disclosure Obligations

CSA STAFF NOTICE 51-308

FILING OF MANAGEMENT'S DISCUSSION AND ANALYSIS

AND NATIONAL INSTRUMENT 51-102
CONTINUOUS DISCLOSURE OBLIGATIONS

Introduction

The CSA have published an advance notice of the expected implementation of National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102).

When implemented, NI 51-102 will specify the form of management's discussion and analysis (MD&A) that reporting issuers, other than investment funds, are required to file. Issuers that are subject to NI 51-102 will be required to file MD&A in Form 51-102F1 for financial years beginning on or after January 1, 2004. As a result, the first MD&A that must be filed in Form 51-102F1 for an issuer with a December 31 year-end will be for the first interim period ending March 31, 2004.

Form 51-102F1 provides that, if the first MD&A an issuer is required to file in that form is not an annual MD&A, the first MD&A must provide all the information required in the annual MD&A. The result is that the first interim MD&A filed for interim periods ended on or after March 31, 2004 will have to contain all elements of the annual MD&A in Form 51-102F1.

Current MD&A requirements will be modified to give issuers the option of filing their annual MD&A for fiscal years beginning before January 1, 2004 in Form 51-102F1. If issuers choose this option, their MD&A for subsequent interim periods would update their annual MD&A.

Questions

Please refer your questions to any of the following people:

December 19, 2003.