I am quite sure that any geologist at the exchange in Canada will state that is expected that any qualified person writing a NI43-101 report should be following professional standards as required by the organization the qualified person is a member of.
Most NI43-101 reports I have seen do outline prior work performed and give recommendations of work and the budget for the same.
Yes of course most exploration work would generally be the same in both countries, though there are a few quirks in how CIMM and SME members may do things in practice as one might expect,and some judgement calls - for example in Canada a geologist will generally consider NI43-101 guidelines and practice more than a USA geologist may consider SEC Guide 7 - because often a geologist in the USA may never have to deal with SEC Guide 7.A Canadian gelogist may recommend extra work in an area he knows the exchange geologist in the past has requested, that an American geologist may not put as much attention too.
In any case minor issues, I quite agree based on what information is out there it is probable that CGFI did not prepare a NI43-101 report,nor a "preliminary" report according to NI43-101 guidelines. Also that SEC would frown upon such assertions ( I am still curious abut the where is the legal prohibition you refer to). Also eventually this company will have a lot of expense and bother delaing with SEC engineering office and probably have to re-file some of their SEC reports and issue some retractions, if it is worth time of SEC engineering office to look at this company.
I do think though you have made your points !
Bigger issue in general in my opinion is this whole issue highlights the type of management CGFI has, and why they have had and will continue to have a credibility problem.But if just a speculation and everyone knows how risky such a stock is, maybe buyers of the stock just dont care.