In the 9th Primary Market Bulletin published on 27 November 2014, the FCA voices concern over lack of compliance with the Disclosure and Transparency Rules ("DTR") 3 – there have been breaches of content and missed deadlines by transactions conducted by PDMRs – and LR 8.2 – there have been instances where issuers have failed to seek the guidance of a sponsor.

FCA is also requesting feedback on proposed changes to the current notes to three technical notes, namely:

  • The ratification of circulars;
  • Transactions by PDMRs; and
  • Hostile takeovers (to remove references to premium listed issuers preparing a 28-day circular (relating to material changes in information relating to the offeror within 28 days of a hostile takeover becoming wholly unconditional), the requirement for which was removed on 1 October 2014).

The consultation period for these amendments closed on 12 January 2015. The Primary Market Bulletin No.9 is available at:

http://fca.org.uk/static/documents/ukla/primary-market-bulletin-9.pdf.

The UKLA draft technical note on ratification circulars is available at:

http://www.fca.org.uk/static/documents/ukla/knowledge-base/tn-204-2.pdf.

The UKLA draft technical note on transactions by PDMRs is available at:

http://www.fca.org.uk/static/documents/ukla/knowledge-base/tn-540-2.pdf.

The UKLA draft technical note on hostile takeovers is available at:

http://www.fca.org.uk/static/documents/ukla/knowledge-base/tn-305-2.pdf.

The eighth bulletin for primary market participants was covered in the October 2014 edition of this publication.

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