The FCA has issued Primary Market Bulletin 21 today focused on Brexit. It covers two issues, the Market Abuse Regulation and Short Selling Regulation (particularly the market makers exemption).
On MAR, it reminds issuers of their duties to notify the FCA in respect of:
- Article 17 – Disclosure of Inside Information: UK MAR (EU MAR as will be retained in the UK through the Withdrawal Act after Brexit…) contains the same disclosure and notification requirements for inside information and delaying disclosure for issuers with financial instruments on UK trading venues. However, for reporting purposes, all issuers with financial instruments on a UK trading venue will be required to send the FCA the notification on delayed disclosure of inside information in addition to any obligation under EU MAR to notify an EU competent authority due to, for example, the issuer being registered in an EU Member State and/or having instruments admitted to trading on an EU trading venue.
- Article 19 – PDMR transactions: UK MAR (“…) contains the same requirements for PDMRs of issuers with financial instruments on UK trading venues for managers’ transactions. Again, PDMRs of all issuers with instruments on a UK trading venue will now need to send the FCA their PDMR transaction reports in addition to any reporting to an EU competent authority under EU MAR, due to the issuer being registered in an EU Member State.