This edition of our European Regulatory Snapshot looks at the key aspects of Consultation Paper 15/35 issued by the FCA on 5 November 2015, in conjunction with ESMA’s guidance released in the Final Report containing Draft Technical Standards on 28 September 2015, in connection with the implementation of the new EU market abuse regime.
This memorandum considers:
- the revised rules governing the disclosure of inside information, with particular emphasis on the amended rules surrounding the delay of public disclosure, and the new procedures for market soundings;
- changes to the existing regime for disclosures of share dealing by persons discharging managerial responsibilities (PDMRs) and the Model Code; and
- changes to the Code of Market Conduct.
This memorandum also highlights some of the key areas of implementation that remain unresolved in both ESMA’s Final Report and the FCA’s Consultation Paper.