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ARTICLE · 20 NOVEMBER 2024

FCA Issues Reminders About MAR – Five Key Takeaways

Travers Smith LLP
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The FCA's Primary Market Bulletin 52 offers key guidance for listed companies on MAR compliance, covering takeover disclosure timing, financial information obligations, CEO appointment reporting, investor communications, and backup PIP arrangements to mitigate information release risks

United KingdomCorporate/Commercial Law
Adrian West
Adrian West
Ben Lowen
Ben Lowen
Aisling Arthur
Aisling Arthur
Klementyna Zastawniak
Klementyna Zastawniak
Beliz McKenzie
Beliz McKenzie
Peter Williamson
Peter Williamson
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At the end of last week, the FCA published Primary Market Bulletin 52 (PMB 52) which provides helpful guidance for listed companies on the practical application of certain aspects of the UK version of the Market Abuse Regulation ("MAR"). While the points covered in PMB 52 are not new, they nonetheless provide some useful reminders for issuers on areas on which the FCA is focusing.

Five Key Takeaways:

1 When a takeover becomes inside information depends on the facts

PMB 52 discusses the point at which a takeover offer becomes inside information and confirms that it will depend on the facts, including the identity of the bidder, the nature and quantum of the offer and the likelihood that it will be recommended by the board of directors of the listed company. The FCA reminds issuers that whether information is "precise" (in accordance with the definition of inside information under MAR) means there must be a more than fanciful chance of the future event

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