Secutor Capital Management Initiates Coverage on Commerce Resources Corp. (April 2014)

SECUTORCAPITAL MANAGEMENT CORPORATION

28 April 2014

COMMERCE RESOURCES CORP

Commerce REO Speedwagonsits Ashram Rare Earth Project

Price:Market Cap:Common Shares:Fully Diluted:52 Wk Range:30 Day Avg Vol:

Source: Stockhouse

$ 0.20$ 33.4 MM167.18 MM188.47 MM$ 0.055 - 0.26302,310

Project:Loca on:Ownership:Commodity:Status:Resource:

Catalysts:

Project:Loca on:Ownership:Commodity:Status:Resource:

Catalysts:

Ashram Deposit (Eldor)Nunavik Region, Northern QC100 %REEPre-Feasibility Stage29.3 Mt 1.90 % TREO (M&I)220 Mt at 1.88 % TREO (Inferred)PFS, metallurgical results, jointventure partnership

Upper Fir Deposit (Blue River)250 km north of Kamloops, BC100 %Tantalum, NiobiumPEA complete48.4 Mt at 197 ppm Ta₂O₅,1610 ppm Nb₂O₅ (Indicated)5.4 Mt at 191 ppm Ta₂O₅,1760 ppm Nb₂O₅ (Inferred)PFS, joint venture partnership

COMPANY SUMMARY

MARKET DATA

TOP HOLDERS

Marquest Asset Management IncZimtu Capital CorpZurcher Kantonalbank

5.36 %2.25 %0.40 %

Ini a on of Coverage

Arie PapernickEquity Capital [email protected](416) 847-1220

Lilliana [email protected](416) 545-1015

V-CCE

Rare earth element (REE) Supply Remains Limited, Concentrated, and Vulnerable. China con nues to dominate world REE produc on, controlling approximately 90% of the market, despite progress made by Molycorp and Lynas. Although China provided the world with ar ficially “cheap” REEs for years, its labour costs are increasing, its reserves are deple ng, and its mines have been abused to the limit. The costs of producing “cheap” rare earths are becoming increasingly unsustainable in terms of the environment, the availability of reserves, the health of its communi es, and the poli cal ramifica ons. China can no longer afford the costs associated with “cheap” rare earths and is beginning to worry about its own domes c supply, as China is its own biggest customer.

The Bottom of the Curve? REE prices have decreased considerably in recent years, although they are generally s ll above where they were in 2009, before fears of constrained supply sent prices sky-rocke ng. Very li le produc on has since come online, implying that REE prices may have over-corrected. Increasing environmental standards, decreasing reserves in China, and minimal new supply indicate that REE prices cannot stay this low indefinitely.

Commerce Resources is one of the most advanced REE juniors in regards to metallurgy, which in the REE space, is everything. The Ashram Project hosts a substan al resource with a well-balanced rare earth oxide (REO) distribu on. The deposit is enriched in light and heavy rare earths, including all five of the cri cal elements. The mineralogy is simple due to the presence of the minerals monazite, bastnaesite, and xeno me which currently dominate commercial processing. Unlike many of its compe tors, Commerce is able to produce a 43.6% total rare earth oxide (TREO) mineral concentrate due to the deposit’s simple mineralogy, allowing significant cost reduc ons.

Valuation. A net present value (NPV) per share of CAD$1.44 was calculated for the Ashram Project based on a 10% discounted cash flow (DCF) model. In addi on to Ashram, Commerce has an advanced niobium-tantalum project in BC, named Blue River, which was not evaluated in this report. Blue River is compelling in its own right due to recent developments in the tantalum space, however, given that Commerce Resources currently trades at around CAD$0.20 and Ashram yields an a er-tax NPV per share of CAD$1.44, including project financing, Commerce Resources is a stock of interest on the merit of Ashram alone.

SECUTORCAPITAL MANAGEMENT CORP

Commerce Resources Corp

Source: Company Filings

Ashram Project Overview Commerce Resources’ wholly owned Ashram Deposit is part of the Eldor Property. Eldor covers 190 square kmin Quebec’s Labrador Trough. Adriana Resources’ Lac Otelnuk Iron Deposit is approximately 85 km to the south and Kuujjuaq, the closest community, is 130 km to the north. Infrastructure in the area is limited.

Ashram is a carbona te deposit hos ng a well-balanced distribu on of all of the rare earth elements,including the five most cri cal metals: neodymium, europium, dysprosium, terbium, and y rium. REE mineraliza on is virtually completely contained within the minerals monazite, bastnaesite, and xeno me,allowing Commerce Resources to use standard processing techniques. In the REE industry, the ability to use conven onal metallurgy and processing is rather unique. Only four REE-bearing minerals out of over 200 haveever supplied the market in a material fashion. These four minerals currently, and historically, dominatecommercial REE processing and are host to the REEs at Ashram.

The Ashram Project is envisioned as a conven onal, open-pit opera on running at a mining rate of 4,000 tpd.Using this mining rate, and assuming a cut-off grade of 1.25% TREO, Ashram has a mine life of 177 years. The2012 PEA assumed that the mixed REE concentrate would be produced at the mine-site, however, subsequenteconomic studies found that it would be more economical to process the mineral concentrate off-site. Commerce is considering loca ons east of Montreal, along the St. Lawrence Seaway. Be er access, to skilledpersonnel and consumables for example, is the most significant advantage of loca ng a processing facility off-site. It makes sense for Commerce to consider this op on given that it can achieve a high-grade mineralconcentrate with 97% mass reduc on (3% mass pull), notably lowering transporta on costs.

Due to Ashram’s advantageous mineralogy, Commerce is able to produce a 43.6% TREO mineral concentrateat a recovery of 70.7%. This is one of the highest-grade REE mineral concentrates, which we are aware of,produced by a junior mining company globally. The 2012 PEA evaluated the economics of producing a mixedrare earth carbonate concentrate (REC) or a mixed rare earth oxide concentrate (REO), both with a purity of 99.9%. There are ready markets for these products since they are the basic feedstock for REE separa on facili es.

Ashram Project Loca on

28 April 2014

2



Parameter UnitSCMC DCF

PEA 2012

RESOURCETotal Tonnes Mined t 34,440,000 35,000,000Total Waste Mined t 6,543,600 6,511,742Mining Rate tpd 4,000 4,000Strip Ra o - 0.19 0.19Average TREO Grade % 1.86% 1.81%Days in Opera on Days 350 350Mine Life Years 25 25MILLINGAverage Annual Mill Throughput tpa 1,400,000 1,400,000Average Annual Mineral Concentrate Produc on (REC) tpa 38,848 36,000Average Annual Mineral Concentrate Produc on (REO) tpa 18,183 16,850Mineral Concentrate Grade %TREO 10 10Overall Recovery % 71% 67%COSTSAverage Cash Opex per kg REO produced CAD$/kg 14 8Average Cash Opex per Tonne Ore Treated CAD$/t 96 95Capital Cost CAD$MM 763 763Total Sustaining Capital Cost CAD$MM incl in G&A incl in G&APROJECT FINANCINGDebt % 100 -Equity % 0 -Average Annual Interest Expense CAD$MM 39 -Total Interest Paid CAD$MM 386 -Average Annual Debt Repayment CAD$MM 80 -Total Debt Repayment CAD$MM 883 -

Parameter Unit SCMC DCF

PEA 2012

PRICES* (CAD$/kg)Oxide Prices Discount % 30% 25CAD:US Exchange Rate - 1.10 1Lanthanum oxide (La) US$/kg 5.6 15Cerium oxide (Ce) US$/kg 5.25 10Praseodymium oxide (Pr) US$/kg 122.5 76Neodymium oxide (Nd) US$/kg 67.5 77Samarium oxide (Sm) US$/kg 9 12Europium oxide (Eu) US$/kg 925 905Gadolinium oxide (Gd) US$/kg 46.5 45Terbium oxide (Tb) US$/kg 825 980Dysprosium oxide (Dy) US$/kg 465 800Y rium oxide (Y) US$/kg 17 28Ashram Basket Price US$/kg 21.70 35.03TAXESIncome Tax Rate % 42.40% -Total Tax Losses Used CAD$MM 5 -Total CCA Used at 30% Annual Rate CAD$MM 764 -PRE-TAX RESULTS (pre-finance)Discount Rate % 10% 10Annual Average Net Cash Flow (LOM) CAD$MM 244 319Pay-back Period Years 5 2.25Total NPV CAD$MM 1,163 2,318Total NPV/Share CAD$/sh 2.48 12.29AFTER-TAX RESULTSDiscount Rate % 10% -Annual Average Net Cash Flow (LOM) CAD$MM 139 -Total NPV CAD$MM 675 -Total NPV/Share CAD$/sh 1.44 -

Ashram DCF Assump ons

Source: Company Filings, Secutor Capital Management Corp

Valuation A 10% discounted cash flow model was used to value the Ashram Deposit. The es mate was based on thepreliminary economic assessment (PEA), released July 2012, with a few differences as noted in the followingtable. Using the assump ons summarized below, which include project financing, Ashram yields an a er-taxNPV per share of $1.44.

28 April 2014

3



Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4Pre-Feasibility StudyFeasibility StudyPermi ngProject FinancingConstruc onCommissioning

20192014ITEM

2015 2016 2017 2018


Assumed Timeline Used in the DCF

Rare Earth Prices

March 2014 prices, quoted by Metal Pages, were used in the DCF. Despite the fact that rare earth prices havecome down considerably since Commerce’s 2012 PEA, the project remains robust. Many rare earth companiesare struggling at these prices and must rely on by-products in order for their projects to remain somewhateconomic. Commerce does not have this problem. Furthermore, Ashram’s balanced rare earth distribu ongives it a be er chance of surviving price weaknesses that may occur for the individual rare earth oxides.

Project Financing

For the DCF model, it was assumed that the Ashram Project will be financed via 100% debt. The debt wasmodelled over a period of 11 years at a 9% interest rate. Addi onally, CAD$28 million in equity was modelled toaccount for expenses related to the comple on of the pre-feasibility and the feasibility study. Thesetransac ons were based on Commerce’s current share price.

Project Timeline

The project meline assumed in the DCF is shown in the diagram below.

28 April 2014

4



The Upside

A number of recent developments are expected to improve Ashram’s economics. These were not taken into account in the DCF calcula on, nor the 2012 PEA, but will be considered in the upcoming pre-feasibility study (PFS).

1. The +40% mineral concentrate The 2012 PEA and the DCF model are both based on a 10% mineral concentrate. Since Commerce Resources can now produce a higher than 40% mineral concentrate, Ashram’s opera ng and capitalcosts should be reduced markedly. Less material will be processed to produce the mixed REO or REC end-products, which will translate into less acid consump on, resulting in lower processing costs. Construc on and equipment costs should also be reduced since a smaller facility and less equipment willbe needed to process less material. The upgraded concentrate should also have a posi ve impact ontransporta on costs. Assigning a value to the impact of going from a 10% to a 40% mineral concentrateis difficult to assess without a detailed evalua on of the impacts on the project in its en rety, therefore it has not been included in the DCF modeled herein. However, the upcoming PFS is an cipated to bebased on a minimum 40% mineral concentrate.

2. Infrastructure developments in Quebec Ashram’s capital costs are about average for the rare earth industry, however, CAD$760 million is s ll a substan al amount, especially in these capital-constrained markets. The 2012 PEA assumes that Commerce will foot the bill on its own. However, it is possible that Commerce may be able to benefitfrom infrastructure developments at Adriana’s Lac Otelnuk Project, 80 km to the south. Lac Otelnuk is one of the largest mining projects in development of all me for Quebec, and will need a large amount of infrastructure including rail, road, and power. Addi onally, although li le has been done to advance Plan Nord, this is s ll a possibility going forward. The Liberal Party, the original proponents of the strategy, have been elected and Philippe Couillard, Quebec’s premier, made Plan Nord an importantpart of his electoral pla orm. Commerce’s proposed road route is in line with Plan Nord’s development plans.

3. Fluorite (fluorspar) a poten al by-product Ashram’s economics could be further improved by including fluorite as a poten al by-product. Fluorite comprises the tailings of the final REE mineral concentrate, and therefore, follows the exact same flowsheet, requiring no addi onal processing to produce. A 94% fluorite concentrate could likely be produced with minimal impact to opera ng expenses and to capital expenditures. Fluorite sells forapproximately US$380 per tonne and has a ready market, opening up the possibility for a future off-takeagreement.

28 April 2014

5



4. Hydrometallurgical plant loca on The PEA evaluated the economics of performing acid “cracking” onsite. A recently completed trade-off study indicated that a loca on off-site will be more economic due to be er access to skilled personnel and consumables. An off-site loca on east of Montreal, along the St Lawrence Seaway, will be used as the base case in the upcoming PFS.

5. Op miza on of the roads The capital costs of the roads have been significantly reduced since the PEA. The op mized route iseasier to build, reducing construc on costs, and requires shorter water crossings. The only itemremaining is to determine the exact loca on of the docking facility and subsequently the final length of the road. Again, these op miza ons will be included in the PFS.

Ashram Deposit: Resources March 2012 Global Mineral Resource Es mate

Cut-off Confidence Category

Tonnage (t)

TREO (%)

LREO (%)

MREO (%)

HREO (%)

MHREO (%)

MHREO/TREO (%)

1.25 Measured 1,590,000 1.77 1.60 0.089 0.085 0.17 9.8% Indicated 27,670,000 1.90 1.77 0.073 0.056 0.13 6.7% Inferred 219,800,000 1.88 1.77 0.068 0.045 0.11 6.0%

March 2012 MHREO Zone Mineral Resource Es mate

Cut-off Confidence Category

Tonnage (t)

TREO (%)

LREO (%)

MREO (%)

HREO (%)

MHREO (%)

MHREO/TREO (%)

1.25 Measured 1,140,000 1.69 1.50 0.098 0.099 0.20 12% Indicated 5,420,000 1.62 1.44 0.091 0.091 0.18 11% Inferred 2,790,000 1.57 1.39 0.085 0.088 0.17 11% LREO (Light Rare Earth Oxides) = La2O3 + Ce2O3 + Pr2O3 + Nd2O3

MREO (Middle Rare Earth Oxides) = Sm2O3 + Eu2O3 + Gd2O3 HREO (Heavy Rare Earth Oxides) = Tb2O3 + Dy2O3 + Ho2O3 + Er2O3 + Tm2O3 + Yb2O3 + Lu2O3 + Y2O3 MHREO (Middle and Heavy Rare Earth Oxides) = MREO + HREO MHREO / TREO, ra o expressed as a percent Note: Global mineral resource es mate includes the MHREO Zone


28 April 2014

6


Recent Drilling at the Ashram Deposit



The most recent resource es mate for the Ashram Deposit was released March 2012. Commerce is currentlycomple ng a 1,000 to 1,500 m infill drill program in order to upgrade the inferred mineral resource to measuredand indicated in prepara on for the pre-feasibility study. The drill program will focus on the Centre Pond areaand is an cipated to sufficiently delineate the Middle and Heavy Rare Earth Element Oxide Zone (MHREO).

The MHREO Zone, as its name implies, is enriched in middle and heavy rare earth oxides due to the presence of the mineral xeno me. It is located in the central por on of the Ashram Deposit, extending from surface to adepth of 178 m, and is expected to be the ini al focus of development ac vi es. An enriched zone of thisnature is rare in carbona te deposits.

Recent infill drilling hit high-grade intercepts including 61.40 m of 2.15% TREO, and 57.36 m of 2.28% TREO.These intercepts are above the average grade of the overall resource. Furthermore, drilling encountered lessin-pit waste rock at surface than was previously modelled in the PEA, lowering the strip ra o, increasing the resource, and reducing costs. Moreover, a couple of step-out holes intersected an extension of the deposit 60 m to the northwest.

28 April 2014

7



26%

46%

5%

17%

2%

0% 1% 0% 1% 2%

La

Ce

Pr

Nd

Sm

Eu

Gd

Tb

Dy

Y

5%8%

19%

37%

1%

16%

2%3%

8% 1%

La

Ce

Pr

Nd

Sm

Eu

Gd

Tb

Dy

Y


REE Distribu on by Tonnage REE Distribu on by Value

Rare Earth Element Distribution

Ashram contains a well-balanced distribu on of all of the rare earth elements, including the cri cal rare earths, Nd, Eu, Tb, Dy and Y. It is neither a light rare earth deposit, nor a heavy rare earth deposit, but is rathersomewhere in-between. Though Ashram’s REE distribu on is 26% lanthanum and 46% cerium, these metals account for only 5% and 8%, respec vely, of the ore’s value. Praseodymium, neodymium and europiumcollec vely account for 72% of the rock value, despite being only 22% of the rock by tonnage. As previouslymen oned, it is highly rare for a carbona te deposit, which is the dominant REE-deposit type in produc on, tobe enriched in these metals.

28 April 2014

8



Applica onGrowth

Rate La Ce Pr Nd* Sm Eu* Gd Tb* Dy* Y* OtherMagnets 8-12% - - 23.4 69.4 - - 2 0.2 5 - -Ba eries 50 33.4 3.3 10 3.3 - - - - - -Metal alloys 26 52 5.5 16.5 - - - - - - -Cataly c converters 5 90 2 3 - - - - - - -Catalysts 90 10 - - - - - - - - -Polishing compounds 5-10% 31.5 65 3.5 - - - - - - - -Glass addi ves 4-6% 24 66 1 3 - - - - - 2 4Phosphors 0-4% 8.5 11 - - - 4.9 1.8 4.6 - 69.2 -Ceramics 4-6% 17 12 6 12 - - - - - 53 -Other 6-10% 19 39 4 15 2 - 1 - - 19 -

Heavy REE

6-12%

4-6%

Light REE Middle REE

Source: IMCOA, Cur n University, Kingsnorth, Na onal Ins tute of Advanced Studies

Use of Rare Earths by Applica on (Percentage)

Although not a heavy rare earth deposit, Ashram s ll hosts appreciable amounts of Tb, Dy, and Y. Thefollowing charts compare Ashram to several well-known REE deposits. Furthermore, the grade of the individualREOs becomes less important if a high-grade mineral concentrate can be produced economically, which Commerce can do. In the end, it is never advantageous for a deposit to have the “right” rare earth distribu on but the wrong mineralogy. The mineralogy determines the feasibility of a project.

Furthermore, Ashram contains the rare earth elements needed by industry. Though many perceive heavy rareearth oxide (HREO) dominated deposits to be more favourable economically, only three of the heavy rareearth elements (HREEs) have ready markets. These are terbium, dysprosium, and y rium. The remaining,erbium, holmium, thulium, y erbium, and lute um, are small, niche markets. The chart immediately belowshows the rela ve quan es of rare earths used in different intermediate products. As demonstrated, asignificantly higher quan ty of light and middle rare earths will be required in the higher growth markets,including magnets and ba eries.

28 April 2014

9



REE Deposit Comparison: Grades for the Cri cal Metals

Neodymium (Nd) Oxide Grade by Deposit

Europium (Eu) Oxide Grade by Deposit

Source: Dahrouge Geological Consul ng Ltd

REE Host Rock TypeCarbona teCarbona te (Laterite)Peralkaline/GranitoidHydrothermal/VeinOther

28 April 2014

10



Terbium (Tb) Oxide Grade by Deposit

Dysprosium (Dy) Oxide Grade by Deposit



28 April 2014

11



Y rium (Y) Oxide Grade by Deposit



Ashram Deposit: Geology Ashram is a carbona te REE-F deposit hosted within the larger REE-Nb-Ta-P-F-enriched Eldor Carbona te Complex, part of Commerce’s Eldor Property. The Eldor Property is situated within the central area of theLabrador Trough, straddling two lithotectonic zones that are separated by a major thrust fault. The area’sgeology is complex. However, the Ashram Deposit is characterized by consistent rare earth mineraliza on throughout, and shows li le dilu on from unmineralized fragments and clasts, resul ng in the amenability ofsimple mining methods. The deposit is covered by only a thin veil of overburden, averaging less than threemetres in thickness, resul ng in an extremely low strip ra o of 0.19. Addi onally, as previously men oned, theore can be processed using standard methods owing to the rare earth mineraliza on being virtually en rely hosted by the minerals monazite, bastnaesite, and xeno me. Furthermore, the fluorite mineraliza on is par oned into the tailings of the final REE mineral concentrate, allowing for no addi onal processing ifCommerce chooses to produce a saleable fluorite concentrate.

28 April 2014

12



The Eldor Carbona te is ellip cal in shape and is es mated to be seven to 15 km long, and three to four km wide. Mineraliza on is separated into three major divisions: early, mid, and late-stage. It is the late-stagecarbona te, central to the complex, which hosts the REE mineraliza on at the Ashram Deposit. Ashram’s rare earth mineralized footprint has been defined for a length of 700 m, for a width 500 m, and to a depth of 600 m.Mineraliza on remains open to the north, to the south, as well as at depth.

Metallurgy The Advantage

For rare earth deposits, there is no standard metallurgical process to separate the minerals from the ore sinceeach deposit will vary in composi on. Therefore, unique processes have to be developed that are specific to the orebody based on its paragenesis, and its mineralogical and chemical proper es, necessita ng expensive research and development costs. Furthermore, REE concentra ons in the host rocks are low with up to 90% of the ore’s mass discarded as waste; this coupled with the ore’s complexity leads to significant separa on andprocessing costs. Moreover, some rare earth deposits may contain radioac ve metals such as uranium and thorium which further complicates the process.

The largest cost of any REE project is processing, and a good por on of processing costs is acid consump on.Processing costs are best reduced by upgrading the ore into a high grade mineral concentrate, reducing theamount of material that must be treated downstream. Commerce is able to reduce the mass of the ore by 97%on-site, producing a mineral concentrate of 43.6% total rare earth oxide (TREO) at a recovery of 70.7%. Forcomparison, Chinese refineries process feedstock from non-ionic clay deposits grading over 30% TREO with recoveries of over 60%. Molycorp and Lynas are also capable of producing mineral concentrates in excess of30% TREO.

Therefore, it appears that this capability is a prerequisite for produc on; however, this is where most junior mining companies struggle although it is the most crucial produc on criteria. Commerce is one of only two REE juniors, that we know of, that are able to produce a higher than 30% TREO mineral concentrate.

28 April 2014

13

Simplified Flowsheet for the Production of a Rare Earth Mineral Concentrate




There are over 200 REE-bearing minerals, yet only four of these have ever been a source of material supply tothe market, and thus dominate commercial processing, both presently and historically. These are monazite, bastnaesite, xeno me, and loparite. However, many rare earth deposits contain mul ple REE-bearing mineralscontribu ng to the overall grade, and many of these have never been commercially processed, leading to complicated flow sheets, and high processing and R&D costs. Significantly, although heavy rare earths are in demand for the Chinese, they only have the capability to liberate HREEs hosted by xeno me, not those hosted by the myriad of exo c minerals making up many of the most well-known HREE deposits. The reason why Commerce’s metallurgy is so advanced is because the REE mineraliza on at Ashram is contained within conven onal REE-bearing minerals, and therefore the metallurgy is well understood. Furthermore, waste rockand mine tailings at Ashram are not considered to be acid-genera ng or radioac ve.

The Process

The simple schema c below illustrates Commerce’s flow sheet for the produc on of a rare earth mineral concentrate. Upgrading begins with a conven onal one-stage beneficia on and flota on circuit which reducesthe mass by over 82%. This step is followed by a weak HCL leach at ambient temperature to remove carbonate,significantly reducing the mass of the material and increasing the grade with essen ally zero REE loss. Currently,acid consump on at Ashram is among the lowest in the industry, requiring only 25 to 90 kg (100% HCl basis) pertonne of whole rock without op miza on. The material is then subjected to Wet High Intensity Magne c Separa on (WHIMS) to remove fluorite and to upgrade the concentrate to 43.6% TREO.

28 April 2014

14




The next step is sulpha on roas ng and leaching to produce the desired end-products. Commerce will con nue to focus on improving recoveries across the flow sheet. A pilot plant to scale-up the process is the next step. It will allow sufficient feed material to be produced for the hydrometallurgical stage so that this por on of the flow sheet can be op mized, and so that Commerce can begin to evaluate its op ons for end-products.

28 April 2014

15



End-Products

Commerce is currently evalua ng several op ons for end-products including a mixed REO concentrate, amixed REC concentrate, and a par al separa on. A par al separa on is not as difficult as a full oxide separa on and will result in end-products such as a cerium oxide product, a didymium product (praseodymiumand neodymium), a SEG mixed oxide product (samarium, europium, gadolinium), and/or an HREO mixed product. Ul mately, the end-products Commerce produces will depend on the needs of a JV partner or otherstrategic partner. REE processors, such as Rhodia, would look to buy REO concentrates, whereas end-users aremore interested in buying specific oxides. Again, the simplicity of Commerce’s REE mineralogy allows for a highgrade mineral concentrate to be processed into solu on, resul ng in fewer impuri es and fewer difficul es inproducing the various end-product op ons.

Quebec Deal with FerroAtlantica: More to Come?

FerroAtlan ca, a Spanish mul na onal that is one of the world’s largest producers of silicon metals, plans tobuild a $375 million silicon metal plant in Quebec. Although the plant’s site has yet to be selected, the Companyexpects that the plant will begin opera ons in late 2016. According to FerroAtlan ca’s Director General, “veryfavourable” condi ons a racted the Company to Quebec including discounted rates for hydroelectricity, a tenyear tax holiday, and financial support from Inves ssement Quebec which could amount to five to ten percentof the project’s capital cost.

Could a similar deal be ini ated between the province and a rare-earth processor? As discussed, due to theWest’s complacency to accept cheap resources from China, as well as a lack of vision for the long-term, thereare very few rare earth processing facili es located in the western world. Rhodia, part of the Solvay Group, isone of the few companies outside of China that has the technology to separate, purify, and produce rare earthintermediate products. Since a number of rare earth deposits are located in Quebec, such a deal would beposi ve in establishing an integrated supply chain outside of China, provided that the deal is supported byprovincial and federal governments in terms of capital and regula ons.

28 April 2014

16



28 April 2014

Rare Earth Primer The rare earth elements (REE) are a group of 15 metals with very similar chemical proper es. This similarity inchemical behaviour is the reason why REEs o en occur together in nature, though in varying, generally small concentra ons. It is also the reason behind the complex metallurgy required to separate each individual REEinto a saleable, high-purity form. To further complicate ma ers, processing technology is specific to each ore body and there is limited exper se outside of China.

Each rare earth deposit contains a different propor on of the 15 rare earth metals. Therefore, a basket pricerepresen ng the unique, average realized price of the separated metal oxides is a common metric used tocompare the rela ve value of different deposits. Generally, prices and rare earth concentra ons are expressed in terms of the specific, corresponding metal oxide (REO) or the total rare earth oxides (TREO) contained in theore.

The rare earth elements are divided into two main groups: light (LREE) and heavy (HREE), based on atomicweight. The majority of rare earth deposits are dominated by light rare earths such as lanthanum, cerium,praseodymium, and neodymium. These metals can make up 75% to 99% of a deposit’s composi on. HeavyREEs have a higher supply risk in the short-term since there are essen ally no sources of produc on outside ofChina. Addi onally, five of the 15 rare earth elements have been designated “cri cal metals”: neodymium(Nd), europium (Eu), terbium (Tb), dysprosium (Dy), and y rium (Y). Cri cal metals are metals of high strategic importance to advanced economies, given their high-tech, military, and green-tech applica ons, and areextremely vulnerable to supply deficits.

The primary applica ons of REEs include polishing powders (14% of the market), metal alloys, as used in Li-ionba eries for example (21%), permanent magnets, which are used in a variety of high-tech applica ons (23%),and catalysts, used in cataly c converters and in oil refining (18%). Recent R&D expenditures have not yieldedany suitable, economic subs tutes to the rare earth metals due to the group’s desirable and unique chemical proper es.

Concerns over the state of the global economy, coupled with Molycorp and Lynas’ start-up troubles, have le many junior rare earth companies priced as though their projects are uneconomic. Assessing the quality ofthese rare earth projects can be difficult given that there are limited historical metrics to rely upon, and un l recently, there have been virtually no explora on and development ac vi es in the sector. That being said,junior companies with the greatest poten al to appreciate in the current market climate will have cash, soundeconomics, the ability to produce a mineral concentrate grading higher than 30%, and a deposit with exposureto the cri cal metals.

17



The Rare Earth Market Rare earth metals are s ll a niche industry. The global rare earth market is valued at approximately US$8 billionin comparison to US$260 billion for iron ore. However, it is a high-growth industry, especially as newer andimproved technologies requiring these materials are developed and implemented. Addi onally, the rare earth market is itself highly technologically driven in that producers and developers need to stay current inmetallurgical and material science research. Having a deposit is not enough; one must be able to economically process the ore to realize value, and as previously men oned, processing methods are unique to each orebody.Metallurgy is much less standardized than for other metals.

The rare earth industry is complicated. Pricing is en rely opaque, demand is difficult to es mate, supply is concentrated in one country, global supply chains are complex, end-use applica ons are numerous, and thereare virtually no public, established producers that seek out junior companies to feed their project pipelines.Furthermore, it is highly poli cally charged. Due to the Chinese monopoly, there is significant uncertaintyregarding the future of rare earth metal markets.

No Production is Sold on the Open Market

Unlike tradi onal base and precious metals, rare earth metals are produced to certain specifica ons given bythe end-user. As a result, REEs are not typical commodi es and are not sold on the open market. Producers ofrare earth metals are required to establish their own markets for their products, which is generally done bysecuring off-take agreements and strategic, end-user partnerships before the produc on stage. Japan is by far China’s largest trading partner for REEs, accoun ng for approximately 66% of all exports (USGS, 2010). As aresult, Japan has been ac vely searching for a viable REE supply to curb this dependence, hence the increasingnumbers of joint ventures between established Japanese companies and junior resource companies.

Pricing: China and the Rest of the World

Generally, prices for REEs are variable and can depend, in part, on the source quoted. Addi onally, there aretwo prices for rare earth oxides: the “China price”, and the “Rest of World price”. Prior to the recent WTO ruling, China was able to set its internal rare earth prices at a significantly lower level than its external (FOB) prices. The lower pricing in China is largely the result of poli cs, decreasing REE export quotas, and the considerable tariffs that are applied to rare earth materials that leave the country. These restric ons guaranteed domes c manufacturers a reliable REE supply as well as significant cost-savings, exer ng pressure on foreign companies to relocate their manufacturing opera ons to China, crea ng jobs and transferringtechnologies.

28 April 2014

18



Moreover, China has two compe ng rare earth industries: legal and illegal. According to a white paper issued bythe Chinese government, from 2006 to 2008, volumes of exported rare earth products from China were 35%,59%, and 36%, respec vely, higher than the official numbers recorded by Chinese customs. In 2011, the rest of the world recorded rare earth imports that were 120% higher than China’s official export numbers. The illegalsmuggling of rare earths metals allows end-users to shop around, further depressing prices.

Politics and China In 2011, China supplied 95% of the world’s rare earth metals. Even with foreign produc on from Molycorp and Lynas, this figure hasn’t changed significantly. The U.S. Geological Survey (USGS) notes China’scontribu on to world produc on in 2013 was 90%. China’s dominance of the industry, due to its lower labourcosts and lack of environmental standards which have priced compe tors out of the market, is a concern for therest of the world. Not only is the supply of cri cal, strategic materials needed for weapons’ systems and keytechnologies concentrated in one country, but that country happens to be one that is not trusted. It is seen bysome as a poten al adversary and by others as unreliable, since many believe that it is not above using itsmonopoly of key resources as leverage in interna onal conflicts, as it allegedly did in 2010 with Japan in its clashover the Senkaku/Diaoyutai Islands.

If given the op on, it seems as though most buyers would rather not deal with China. However, not only doesChina control the raw materials, but it also controls the produc on of the downstream oxides, the associatedmetals, and the alloys. The implica on is that even if new sources of rare earths are established outside ofChina, who will process the material into the high-value products required by modern industry?

The WTO Ruling

From the end of 2010 to early 2011, REE prices rose considerably amid fears that China would con nue torestrict rare earth exports. China reduced its quota for rare earth exports from 50,000 tonnes in 2009 to 30,000tonnes in 2010, where the quota remains. It argues that the quotas were adopted in order to curb the massive environmental damage associated with its rare earth industry, and to help conserve its finite resources. These claims appear to have some validity. In 2010, China was producing 97% of the world’s rare earth metals butonly had 30% of the world’s reserves, according to China’s Ministry of Commerce. In 1996, China had 43% ofworld reserves. However, due to the lack of transparency, data coming out of China is highly unreliable and global rare earth reserve es mates vary widely.

28 April 2014

19



China is able to sell rare earth metals so cheaply, deterring new market entrants, because of its disregard for theenvironment, something that is not permissible in the western world and not sustainable anywhere. The implica on is that for several years, rare earth prices have been kept ar ficially low since resource scarcity,and social and environmental damages were never priced into the equa on. China is star ng to improve its environmental prac ces and new foreign producers have come online that must follow more stringentenvironmental standards, meaning that China cannot con nue to sell rare earth metals this cheaplyindefinitely. However, the global community is hesitant to take these claims at face value.

In September 2010, Japanese companies accused China of blocking REE shipments to Japan for three weeks,believing Beijing was using these economically vital materials as leverage in a bilateral conflict. The US, the EU,and Japan ini ated a complaint to the World Trade Organiza on (WTO) on the grounds that Chinese export quotas on rare earths broke world trade law by allowing China’s domes c manufacturing industries an unfairadvantage over the rest of the world, in terms of rare earth prices and availability. This past March, the WTOannounced that it agreed. The quotas were not handled uniformly, resul ng in an obvious advantage forChinese-based companies. China is expected to appeal the ruling.

Will the WTO Ruling Change Anything?

The WTO is expected to maintain its decision, meaning that China will have to abolish its quota system within areasonable meframe. What happens next will depend on whether China priori zes its monopoly, or theextensive environmental damage caused by its rare earth mining prac ces. If one examines the current state of Bayan Obo, China’s largest rare earth mine, China’s environmental problems actually seem understated. However, there are some that believe that China will con nue to undercut emerging foreign producers in order to maintain its control over the industry. Another considera on to keep in mind is that China’s domes cdemand for rare earth products is also increasing, which could limit its ability to keep prices ar ficially low.

Bayan Obo: How Bad is Bad?

Bayan Obo, situated near Baotou in Inner Mongolia, is China’s single largest supply of REEs and contributes toalmost half of the world’s annual produc on. No one outside China knows what the current reserves are,however, a 1998 USGS report cited resources of 1,500 million tons of iron at a grade of 35%, and at least 48million tons of rare earth oxides at an average grade of 6%. Rare earth produc on from Bayan Obo con nued toramp up in the 2000’s, so it is doub ul that the current mine life is as rosy as some may believe. The Chinesegovernment claims that a er over 50 years of intensive mining, rare earth reserves in Baotou are only one thirdof the original volume in the main mining areas.

28 April 2014

20



According to Chinese-controlled media, every year seven to eight million tons of waste is dumped into BayanObo’s 11 square km unlined tailings pond. Outdated processing prac ces have contributed to soil erosion, pollu on, acidifica on, and have severely limited the surrounding area’s agricultural land. Many studies havebeen conducted on the heavy metal content of the soils surrounding the mine, which are high in arsenic andfluorine, as well as the toxicity of the land and the epidemiological consequences. However, these studies areonly available in Chinese print journals and much of the data is s ll deemed “sensi ve informa on” (Klinger,University of California, Berkeley).

The toxic, radioac ve waste generated from the processing of rare earth metals at Bayan Obo is seeping into the groundwater, making its way toward the Yellow River. Furthermore, some worry about the tailings dyke failing,a common occurrence in China in recent years, especially due to the age and the mismanagement of the BayanObo opera on. If such an event were to occur, the consequences would be disastrous due to Bayan Obo’sproximity to the city of Baotou and the Yellow River. 200 million people depend on the Yellow River for drinking water, irriga on and agriculture, fishing and industry (Klinger, University of California, Berkeley).

It should be clear that the environmental burden carried by China to supply the world with “cheap” rare earthsis high. It is unfortunate that some believe China is using the environment as an excuse in order to procure afavourable ruling from the WTO. If the world’s first ins nct is to distrust informa on coming out of China, is itpossible then that perhaps China is underrepor ng the extent of the environmental damage caused by rareearth mining and processing? Admi ng to the full scale of the damage, how greed and reckless managementhave endangered its own popula ons and the environment would likely be embarrassing for China’spolicymakers. However, it seems as though there is li le interna onal understanding of the true cost of “cheap” rare earth metals.

The Chinese are likely struggling with their rare earth assets due to decades of inefficient, wasteful processing and non-existent environmental standards. The reality is for how long can one abuse its mines before seeing these consequences? China has recently begun efforts to remedy the situa on, including industry consolida on to improve control, implemen ng stricter environmental standards, improving its own extrac ve processes and recoveries, and cracking down on viola ons of the laws and regula ons. However, the point is that no onereally knows the full extent of the damage done by China’s rare earth industry, and the shape these mines arein. Could it be that China will have to secure both a supply of heavy rare earths and a supply of light rare earths sooner than the rest of the world an cipates?

28 April 2014

21



Bayan Obo and Elevated Areas of Radioac vity

Proximity of Baotou Iron and Steel Plant (BTISP) to Baotou City

Source: Tsinghua University

Source: Tsinghua University

28 April 2014

22



Rare Earth Demand: China and the Rest of the World (ROW)

Source: Professor Dudley J. Kingsnorth, IMCOA, Cur n University

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

2004 2006 2008 2010 2012 2014E 2016E

ROW

China

Supply and Demand World demand for rare earth oxides was es mated at 115,000 t for 2012 compared to 90,000 t in 2004, anincrease of almost 28%. China’s share of worldwide demand was es mated at 64% of this total in 2012,compared to 42% in 2004. As China’s and the rest of the world’s demand for rare earths increase, access to a reliable supply of these metals is becoming a great concern.

Grandview Research Inc predicts that the market for rare earth elements will grow to US$10.96 billion by 2020. That equates to an increase of 37% over five and a half years. Asia Pacific, the largest customer of REE in2013, is expected to see the largest growth in consump on during this period. Economic growth and the pace ofdevelopment for new technologies are the two main factors driving demand for REEs.

Build the Supply and the Demand will Follow

A key issue dampening demand for both light and heavy rare earth metals is the scarcity of a reliable, stable, and secure supply. The probability of a supply disrup on from China may be fairly low, although, if such anevent were to occur, the economic and defense consequences would be severe. Due to this risk, it isunderstandable that manufacturers are hesitant to invest serious money into developing product lines that userare earth materials.

28 April 2014

23



Mountain Pass (US) Down-Stream Processing (Majority in China) Resources Chemicals & Oxides Magne c Materials

& Alloys Rare Metals

Segment Revenue ($MM) 11.3 55.4 59.3 14.5 Volume (tonnes) 1,034 1,760 1,353 58 Revenue Share 8% 39% 42% 10% Volume Share 25% 42% 32% 1% Source: Molycorp

Molycorp: Breakdown of Revenue

Instead of inves ng in these supply chains, manufacturers are dedica ng R&D money to finding rare earth subs tutes, which is no easy task due to their desirable and unique properties, to recycling rare earth metals, or to reducing the amount of REEs used in their products. For example, electric car manufacturers like BMW’sMini and Tesla use motors that do not require rare earth magnets (Reuters). The implica on is that certain energy-saving or resource-saving technologies are not being used to their full poten al because of a lack of raw materials. Another example is fluorescent light bulbs, which are twice as efficient as the current standardbut use rare earth-based phosphors. In 2009, the US Department of Energy tried to phase out the currentstandard and switch to fluorescent light bulbs, however, companies like General Electric opposed the ini a ve because it claimed that it would not be able to secure enough rare earths to manufacture the new bulbs (Jones,Yale).

The lack of a secure supply of rare earths is a problem, especially as newer and be er technologies are developed that require the use of these exo c metals. End-users will need to have confidence in their supply chains before new and improved applica ons requiring rare earth metals can be developed and commercialized.

Have Molycorp and Lynas Changed Anything?

Lynas (LYC-AU) and Molycorp (MCP-US) are the first two companies to develop rare earth mines outside ofChina in recent years. Both of these mines produce light rare earth oxides and are located in Australia and inCalifornia respec vely. Lynas announced produc on of 1,089 tonnes REO for the March 2014 quarter andexpects to ramp up to 11,000 tpa by June 2014, despite its financial difficul es. Molycorp, although con nuing to operate at a loss, announced produc on of 1,000 tonnes of REO for the fourth quarter and an cipates that the mine will produce below its design capacity of 19,050 tonnes in the first half of 2014. However, Molycorp is virtually a Chinese company, and Lynas has pre-sold most of its produc on to Sojitz Corp, one of Japan’s largestsellers of rare earth metals.

Molycorp essen ally became a Chinese company a er its merger with Neo Materials in 2012. Molycorp’s rareearth ore is mined at Mountain Pass in California, however, it ships the majority of the mineral concentratesproduced to Neo Material’s facili es in China for further processing. The following chart breaks downMolycorp’s revenue and produc on volumes for the fourth quarter of 2013.

28 April 2014

24



As demonstrated, only 8% of the total revenue and only 25% of the total volume of goods produced is derivedfrom the US-based Mountain Pass Mine. The majority of Molycorp’s revenue (92%) and the majority of itsproducts sold (75%) are from higher-value processed goods. Molycorp’s facili es are largely Chinese-based. Ifthe world is looking to diversify its rare earth supply, does it change anything to mine and process the rawmaterials in the US, ship these to China for addi onal down-stream processing, and then ship these products to the rest of the world, including back to the US?

Lynas is different. It mines its ore at Mount Weld in Australia and then processes it in Malaysia. It has a ten yearoff-take agreement for over 9,000 tonnes per year with Sojitz Corp. China has tried to acquire both Molycorpand Lynas in the past. In 2005, China made a bid for Molycorp but was blocked by the US government. In 2009,China tried to buy a controlling interest in Lynas but was blocked by the Australian government. PerhapsChina’s intent was solely to protect its monopoly on the industry, however, it is important to keep in mindthat China has a history of thinking long-term. Could it also be thinking of its rare earth supply for domes cconsump on? In either case, developing addi onal mine capacity for the REEs is only a part of the solu on. Inorder to truly diversify supply, down-stream processing facili es must be constructed outside of China to fulfill growing demand for REEs.

The Case of Cerium and Lanthanum: Are these really Dead-Weight?

Cerium and lanthanum are two of the lowest-value rare earth metals in terms of price. They are also the mostabundant, making up over 75% of the typical rare earth deposit, and are therefore in greatest supply,domina ng China’s, Molycorp’s, and Lynas’ produc on profiles.

Once Molycorp and Lynas ramp up to full produc on, the consensus seems to be that the market will be saturated with light rare earth metals and that these prices will con nue to fall to below pre-2010 levels, ceriumin par cular. However, it is important to keep in mind that cerium has been in oversupply for at least the lasttwo decades, and it s ll has a market. 49% of the bastnasite ore at Molycorp’s Mountain Pass Mine consists ofcerium. However, in a conference call, Molycorp stated that roughly 25% of the cerium produced is used as feedmaterial for further processing, and all of these cerium products were sold. The implica on is that there is demand for higher value cerium products, but maybe not as much demand for basic cerium oxide.

Along these lines, Molycorp is increasing its downstream cerium products through the produc on of ceriumspecial es and through proprietary products such as SorbX. SorbX is a water treatment product that was launched into municipal industrial wastewater treatment markets. It is a poten ally large-volume applica on that could see a growth rate of 6-10% between 2015 and 2016, according to the Industrial Minerals Company ofAustralia (IMCOA). The product’s success could significantly increase the amount of cerium sold throughfinished products.

28 April 2014

25



In 2013, according to Grand View Research Inc, cerium dominated the global rare earth market, accoun ng for40% of total rare earth metal consump on. A primary use of cerium and lanthanum is in catalysts, which makesup 20% of the global market for rare earth metals. Grandview expects that catalyst demand, and consequently demand for cerium and lanthanum, will drive the rare earth market for the next six years owing to increasedindustrializa on and oil and gas extrac on ac vi es in Asia Pacific, La n America, and the Middle East.

Catalysts are used in a number of industries such as automobiles, metallurgy, phosphors, and glass. A dominantpart of this market segment is fuel cracking catalysts (FCC), which are used to produce gasoline, dis llate, andother higher-value products like butane and propane. The global petroleum refining catalysts business was valued at US$4.5 billion in 2012 (Chemical Week) and is expected to grow 5.8% per year to $19.5 billion in2016, according to World Catalysts, due to rapid growth in Asia, led by China, and the Middle East. In 2013,according to W.R. Grace, the FCC catalysts market was flat since refinery start-ups were offset by closures in the Atlan c Basin and Japan. W.R. Grace believes that, following regular seasonal weakening in the current quarter,FCC sales should return to growth going forward.

Again, China Leads the Way

As pundits an cipate a “hard landing” for the Chinese economy, China con nues to buy the world’s resources,its most recent acquisi on being the US$6 billion Las Bambas Copper Mine. China has a much longer-term investment meline than the western world. Therefore, regardless if the Chinese economy is slowing, it clearly s ll requires resources to sustain future economic growth and increasing consumer demand.

Domestic consump on, the environment, and energy efficiency are priori es for the country, as set out in its most recent Five-Year Plan, termed the “Green Plan”. Growth in these areas will require rare earths metals,whether for cell phones, laptops, electric cars, or wind turbines. Specifically, China has set a goal of having one million electric vehicles on the road by 2015. Last year, for the first me, there were more electric cars sold in China than in the US.

China does not have an unlimited amount of feed stock for its rare earth processing industry, and the fact that itis beginning to sign MOU’s with junior explora on companies demonstrates this concern. China may be ge ng nervous about its domes c supply and it is its own largest customer. As a result, paying higher prices to importthese materials from the US, Russia, India, or Australia is not in its best interest.

MOUs are highly preliminary in nature, but they are s ll encouraging for the rare earth industry. China’s rareearth reserves are deple ng, especially for heavy rare earths which are thought to only have ten to fi een years le . However, China has significant over-capacity in smel ng and separa ng, but only for the three mineralsthat it knows how to process, which are xeno me, bastnaesite, and monazite.

28 April 2014

26



Conclusion It is difficult to decide what to make out of the data coming from China due to the lack of transparency, thestate-controlled media, and the fact that poli cs o en encroaches on business interests. China’s unregulatedREE produc on prac ces, its apathy towards the environment, and its low labour costs have allowed it to dominate the rare earth industry all these years. However, it appears that the costs of producing “cheap” rareearth products are beginning to outweigh the benefits from the Chinese perspec ve, and as a result, China’srare earth industry is undergoing a number of changes that will make rare earth produc on more expensive.

In the past, China’s priority was to industrialize as quickly as possible, which it did using a low-cost, export-oriented model. China’s rare earth monopoly supported this goal, boos ng exports and growing the economy.However, the repercussions of this unbridled growth are star ng to catch up. The country is trying to transi on from export-oriented growth to growth fueled by domes c consump on, and as previously stated, China is itsown largest REE customer. As China begins to look elsewhere to secure new REE feedstock, perhaps the rest ofthe world should do the same, given the strategic importance of these metals to military and to industry. To that end, why not look to Quebec?

Rare earth projects outside of China with feasible metallurgy and exposure to the cri cal rare earth oxides are quite limited. Many rare earth juniors, though they may have this exposure, are not capable of producing asaleable mineral concentrate, making their projects extremely risky. Commerce is one of the most advanced juniors simply because it meets this key development requirement, even though a feasibility study has not yetbeen completed.

Unlike many other projects, Ashram is made up of minerals that have a known processing procedure.Management believes that it can advance Ashram fairly quickly, depending on financing. Its main focus will beto con nue to advance the metallurgy and to secure a joint venture partner. Commerce is almost at the stagewhere it can begin to focus on the hydrometallurgy and on the evalua on of end-products.

28 April 2014

27

The information contained in this report was obtained from sources we believe to be reliable at thetime obtained but neither Secutor Capital Management Corp nor its employees, agents, or information suppliers can guarantee that such information is accurate or complete and it shouldnot be relied on as such.

Any opinions expressed herein reflect our judgement at this date and are subject to change. This commentary is based on information that is believed to be accurate at the time of writing and is subject to change. All opinions and estimates contained in this report constitute Secutor CapitalManagment Corp’s judgement as of the date of this report, are subject to change without noticeand are provided in good faith but without legal responsibility. Interest rates, market conditionsand other investment factors are subject to change. Past performance may not be repeated.

Secutor Capital Management Corp and/or employees from time to time may hold shares, options or warrants on any issue included in this report and may buy or sell such securities.

Secutor Capital Management does and seeks to do business with companies covered in itscommentary. As a result, investors should be aware that the firm may have a conflict of interest that could affect the objectivity of this report.

This commentary is intended for use only in jurisdictions where Secutor Capital Management Corpis registered and is not to be construed as an offer or solicitation to buy or sell any security.

Secutor Capital Management Corp accepts no liability whatsoever for any loss arising from anyuse or reliance on this commentary or the information contained herein. Any reproduction inwhole or in part of this commentary without permission is prohibited.

This commentary is furnished on the bases and understanding that neither Secutor CapitalManagement Corp nor its employees, agents, or information suppliers is to be under anyresponsibility or liability whatsoever in respect thereof.

Member of the Investment Industry Regulatory Organization of Canada and the Canadian Investor Protection Fund.


Commerce Resources Corp 28 April 2014

28

Investor Relations

Secutor Capital Management Initiates Coverage on Commerce Resources Corp. (April 2014)