On 22 May 2018, CLLS and Law Society Company Law Committees' Joint Working Parties published an updated MAR Q&A. The Q&A have been updated to explain how Article 19 MAR applies to issuers that have only debt financial instruments admitted to trading on an EU trading venue.
As detailed in the updated Q&A, Article 19 applies to persons discharging managerial responsibilities of debt issuers and the persons closely associated with them if the debt instruments are admitted to trading on an EU trading venue. Article 19 does not apply if the debt instruments are not themselves admitted to trading on an EU venue, unless they are linked financial instruments in relation to the traded debt.
The updated Q&A can be accessed here:
http://www.citysolicitors.org.uk/attachments/category/114/CLLS%20and%20Law%20Society%20MAR%20QA%20-%20updated%2022%20May%202018.pdf
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
