Our Legal and Primary Markets Expert Groups contributed to our response to the European Commission's request for feedback regarding its legislative proposals to amend aspects of the Market Abuse Regulation and the Prospectus Regulation.
Overall, we believed that the proposed amendments go some way to reducing the administrative burden and the high compliance costs faced by SME growth market issuers. In particular, we welcomed the proposals to create an alleviated ‘transfer prospectus’ for companies listed for at least three years on an SME growth market seeking admission of their securities to trading on a regulated market, or both an admission and a new offer of securities on a regulated market.
Similarly, we welcomed the amendment that will give SME growth market issuers two extra days to disclose the transactions of a Persons Discharging Managerial Responsibilities (PMDRs) and Persons Closely Associated (PCAs) after receiving the notification themselves from the relevant PMDR or PCA.
Nonetheless, we urged the European Commission to consider enhancing the alleviations available to SME growth market issuers with regards to notifying the delayed disclosure of inside information and insider lists further.
We also commented that he proposal to exempt private placements from certain aspects of the market sounding regime should not be limited to private placements of bonds, but extended to equity too.