Our Legal, Primary Markets and Secondary Markets Expert Groups contributed to our response to the FCA's proposed changes to its technical note regarding periodic financial information and inside information.
We questioned whether the proposed changes to the Knowledge Base provide issuers with additional understanding of periodic financial information and inside information that is not already addressed by ESMA. We suggested that, rather than cross-referencing by way of a hyperlink to ESMA’s MAR guidelines for the disclosure of inside information in the Technical Note, it would be ultimately more beneficial to issuers to either simply direct issuers to those guidelines or, if the FCA insists on having this Technical Note, to quote verbatim the guidelines and provide a reference in a footnote.
