Sdomae, I find the regulation for the NCIB not very clear. Paragraphs 7.1-7.3 of the NI 55-104 seem to say a different thing from a Q&As document on SEDI (See below). My interpretation (I'm not an expert) is given Allana released the details on their transaction within a short period in a document posted on SEDAR, they didn't have to make an official filling on SEDI (the famous "Nature Code 38 – Redemption, retraction, cancellation, repurchase" that people are used to).
When does a SEDI issuer file an issuer event report versus a material change report
A SEDI issuer files an issuer event report when an event affects the entire class of securities in the same manner. This may also be a material change in which case the SEDI issuer will also need to file a material change report in SEDAR. However, not all material changes are issuer events. For example, while a company buy-back of shares might be considered a material change, it would not be an issuer event to be filed on SEDI.
PART 7 EXEMPTIONS FOR NORMAL COURSE ISSUER BIDS AND
PUBLICLY DISCLOSED TRANSACTIONS
7.1 Reporting exemption for normal course issuer bids – The insider reporting
requirement does not apply to an issuer for an acquisition of a security of its own
issue by the issuer under a normal course issuer bid if the issuer complies with the
alternative reporting requirement in section 7.2.
7.2 Reporting requirement – An issuer who relies on the exemption in section 7.1
must file an insider report disclosing each acquisition of securities by it under a
normal course issuer bid within 10 days of the end of the month in which the
7.3 General exemption for other transactions that have been otherwise disclosed
– The insider reporting requirement does not apply to an issuer in connection with
a transaction, other than a normal course issuer bid, involving a security of its
own issue if the existence and material terms of the transaction have been
generally disclosed in a public filing on SEDAR.