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How long are the FCA giving for us to produce our Insider Lists?

If the FCA initiate an investigation into the trades which occurred prior to an announcement of price sensitive information, they will request that the Issuer provide the full Insider List at a given date. Remember that this Insider List should include all the Issuer’s insiders plus all the insiders at third party advisors (printers, accountants, lawyers, investment bankers etc.) In discussions with the FCA, they have made it clear that the List will be required within two days of the request. Such a tight timescale should not be a real surprise but it does draw attention to the need to have your third parties completely up to speed and able to provide you with their data in acceptable form

How many Insider List requests have been issued to date by the FCA?

Your MAR insider list processes will only be put through their paces when the FCA (or other competent body) requests your Insider List at a specific date. Whilst we have many clients who have implemented IMTrack to deal with the maintaining of MAR-compliant Insider Lists, only one company has received a request for their list in the period since 3 July 2016. As a result of this request, the FCA have provided some further advice to the Issuer concerned about the narrative explanations that should be included in the Insider List; we will publish more on this shortly. We have been in contact with the FCA in an attempt to identify the total number of Insider List requests made since 3 July 2016

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