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Our Legal Expert Group contributed to our response to ESMA's Draft Technical Standards on the Market Abuse Regulation. We responded to changes regarding market soundings, insider lists and persons discharging managerial responsibilities as these areas will have the greatest impact on small and mid-size quoted companies. We noted our particular concern with the proposals on insider lists, as we believe that the information proposed by ESMA is far too detailed and will be burdensome for issuers to provide. We argued that the contents of such lists should be proportionate and take into the account the purpose for which insider lists are required. We also noted that there could be data protection issues with the amount of information required to be kept by issuers and their advisors. Regarding market soundings, we argued that it is not appropriate or proportionate for provisions and procedures which a regulated firm is required to have in any event (for example under MiFID) to apply to issuers.

Click here to download the response (pdf)

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