The Issuer retracted disclosure about a "PEM category" (potential economic material category) which is not a category of mineral resources prescribed by CIM as required under Section 1.2 of NI 43-101.

The Issuer filed an amended and restated material change report (the Amended MCR) in respect of its material change report originally filed on December 16, 2022 (the December 2022 MCR). The December 2022 MCR was filed in connection with the offering by the Issuer of 12% Second Lien Notes and detached warrants, including to certain related parties of the Issuer. The December 2022 MCR did not include the required disclosure regarding insider participation or disclosure in accordance with Multilateral Instrument 61-101 Protection of Minority Securityholders in Special Transactions (MI 61-101) with respect to the offering. At the request of Staff, the Issuer filed the Amended MCR, which Amended MCR includes the previously omitted related party disclosure required under MI 61-101.

The Issuer did not previously file its Strategic Alliance Agreement as a material contract as required by National Instrument 51-102 Continuous Disclosure Obligations.

The Issuer (1) filed a material contract (2) amended and restated annual financial statements to correct 2021 figures, correct the audit report and provide disclosure required by IAS 8 and (3) amended and restated accompany MD&A to include disclosure required by Item 1.4(d) of Form 52-102F1.

The Issuer amended and restated interim financial reports for the period end March 31, 2023 and June 30, 2023 to add disclosure that the financial statements were not reviewed by the Issuer’s auditor. The accompanying MD&A were also amended and restated to address deficiencies related to discussion of operations. The Issuer also filed a Form 52-110F2 Disclosure by Venture Issuers which should have been previously disclosed.

The Issuer did not previously file its loan agreement with Sygnum Bank AG, as well as documents incorporated by reference into the loan agreement, and its agreement with Foundry USA Pool as material contracts as required by National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102). The Issuer also refiled the loan agreement and the July 19, 2023 amendment to the loan agreement without certain redactions as required under NI 51-102.

The management reports of fund performance for the annual period ended December 31, 2014 and interim period ended June 30, 2015 were restated to correct the trading expense ratio for the periods ended December 31, 2014 and June 30, 2015.

The Issuer filed an amended technical report on the Okanjande property to address disclosure compliance issues. The Issuer also revised its investor materials to remove aspirational production targets for its mineral projects not yet supported by technical reports.

In connection with the Commission’s review of the Issuer’s continuous disclosure record, the Issuer filed (i) the letter from its former auditor related to the September 22, 2022 notice of change of auditor filed in accordance with section 4.11(6) of National Instrument 51-102, and (ii) the statement of executive compensation for the year ended April 30, 2022 in accordance with section 11.6 of National Instrument 51-102, both of which were required to be filed at earlier dates.

The Issuer filed an amended technical report to remove certain disclosure with respect to a “Blue Sky Scenario” regarding the Detour-Fenelon Gold Trend Property’s potential as well as certain appendices providing additional disclosure regarding the electrical and ventilation infrastructure of the Fenelon Gold project.

The Issuer filed an amended and restated technical report on the Kharmagtai Project to address several disclosure deficiencies and provide additional clarification.

The Issuer filed an amended and restated technical report on the Boroo and Ulaanbulag Project to address several disclosure deficiencies including the qualified person and associated certificate, use of the technical report for internal purposes only, and rounding the mineral estimates to appropriate significant figures.

The Issuer filed a clarifying press release to provide a more fulsome update including dollar amounts of monthly sales orders, the amount of June sales orders ,and a description of advertising and promotion expenses for the same periods.

The Issuer did not previously file its various credit agreements with the Bank of Montreal as material contracts as required by National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102).

The Issuer has refiled its primary credit agreement on SEDAR+ following a routine continuous disclosure review by Staff of the Ontario Securities Commission. Staff requested that the Issuer refile the primary credit  agreement with descriptions of redacted information and with certain redactions removed in accordance with subsection 12.2(5) of National Instrument 51-102 Continuous Disclosure Obligations.

In connection with a continuous disclosure review by Staff of the Ontario Securities Commission, the Issuer has filed a Statement of Executive Compensation for the fiscal year ended June 30, 2023 and Articles of Amendment changing the name of the Issuer from Pinehurst Capital 1 Inc. to Silver Bullet Mines Corp. The documents were not previously filed as required pursuant to subsections 11.6 and 12.1(1)(a) of National Instrument 51-102 Continuous Disclosure Obligations, respectively.

The Issuer did not carry forward material information from a past PEA Technical Report into the current technical report, the Updated Ikkari MRE. Publicly available disclosure also contained references to the past PEA Technical Report, which was unsupported by the current Technical Report. PEA related disclosure was removed from the website and corporate presentation and language was added to the short for prospectus to carve out the PEA from the 2024 AIF detailing the PEA can no longer be relied upon. A press release was also issued detailing the PEA can no longer be relied upon.

The Issuer amended and restated its audited annual financial statements for the year ended December 31, 2022 as well as its interim financial reports for the quarters ended March 31, 2023, June 30, 2023 and September 30, 2023 to correct an error in the application of International Financial Reporting Standards to measure the expected credit losses for a loan package that had been made to a borrower in relation to a large residential development property and has been impaired. The accompanying Management’s Discussion and Analysis (MD&A) for the year ended December 31, 2022, and for the periods ended March 31, 2023, June 30, 2023 and September 30, 2023 were also amended and restated to include corrective disclosure related to the expected credit losses of the loans.  As a result of the corrective disclosure re-filings the Issuer also re-filed certifications of interim and annual filings for each MD&A in compliance with National Instrument 52-109 Certification of Disclosure in Issuers’ Annual and Interim Filings.

The Issuer amended and restated its audited annual financial statements for the year ended December 31, 2022 as well as its interim financial reports for the quarters ended March 31, 2023, June 30, 2023 and September 30, 2023 to correct an error in the application of International Financial Reporting Standards to measure the expected credit losses for a loan package that had been made to a borrower in relation to a large residential development property and has been impaired. The accompanying Management’s Discussion and Analysis (MD&A) for the year ended December 31, 2022, and for the periods ended March 31, 2023, June 30, 2023 and September 30, 2023 were also amended and restated to include corrective disclosure related to the expected credit losses of the loans.  As a result of the corrective disclosure re-filings the Issuer also re-filed certifications of interim and annual filings for each MD&A in compliance with National Instrument 52-109 Certification of Disclosure in Issuers’ Annual and Interim Filings.

The Issuer filed an amended and restated technical report on the Marathon Palladium-Copper Project to revise certain disclosure involving Item 3- Reliance of Other Experts.