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Our Legal Expert Group contributed to our response to ESMA's Draft Technical Advice on Possible Delegated Acts Concerning the Market Abuse Regulation. We responded to the questions on Managers' Transactions. While welcomed ESMA providing guidance on the transactions that are required to be notified, we noted a number of concerns on the measures proposed. Regarding the the use of a “weighting approach” in relation to indices and baskets, we noted that we would support the principle of a weighting approach being taken to baskets and indices and agree that this should be extended to investment funds. However, we questioned whether this could impose an impracticable burden on a PDMR where a fund's value fluctuate on a regular basis.

Click here to download the response (pdf)

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