Anyone who works in or for a listed company needs to know about the changes coming with the Market Abuse Regulation (MAR).
The MAR will replace the current market abuse regime and apply to AIM companies as well as those on the Main Market.
There will be different "closed periods" and the exceptions will be narrower
All issuers must keep "insider lists"
Record keeping and retention (for five years) will be even more important
There will be substantial changes to the FCA Handbook, including the removal of the Model Code and the Code of Market Conduct
The MAR is European legislation with direct effect. Although the MAR comes into force in less than 6 months time, the regulatory technical standards and delegated acts that the European Commission is mandated to make under the MAR have not been finalised, which means that the FCA’s consultation CP15/35 was not published until November and the London Stock Exchange has not yet started its consultation on changes required to the AIM Rules.
Given the short time until MAR implementation, you should be thinking about changes to share dealing codes and processes and procedures now. If you would like to know more, please contact your usual partner at Charles Russell Speechlys or Victoria Younghusband.
Corporate partner Victoria Younghusband is chairing the Joint Working Group of the Company Law Committees of the City of London Law Society and the Law Society, which has been leading the response on MAR implementation to the FCA and the LSE, as well as to the Commission.
This commentary was written by Victoria Younghusband. For more information please contact Victoria on +44 (0)20 7427 6707 or at firstname.lastname@example.org.