This is an unofficial consolidation of National Instrument 45-106 Prospectus and Registration Exemptions reflecting amendments made effective January 1, 2011 in connection with Canada’s changeover to IFRS. The amendments apply to an offering memorandum that includes financial statements for periods relating to financial years beginning on or after January 1, 2011. This document is for reference purposes only and is not an official statement of the law http://www.bcsc.bc.ca/uploadedFiles/securitieslaw/policy4/post-IFRS_45-106[NI]-rev.pdf
Still not sure I get if these are open marker buys or private placements? I wonder if this circumvented the BCSC trading halt that was part of the CTO?