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. To our surprise, they do not record this in one place. Their investigatory processes usually commence with the receipt of a STOR (a Suspicious Transaction and Order Report). These typically originate from a financial intermediary (stockbroker, market maker investment house etc.) and are the alerting mechanism to the FCA. They may receive multiple STORs in respect of one company announcement and, whilst these are brought together in respect of the particular company concerned (so as to avoid multiple requests of an Insider List for one announcement), they do not keep a control sheet of all the requests that are made by all their investigators.
However, we are not completely in the dark. For some time the FCA have published the numbers of STORs (previously called STRs) received on a monthly basis and this can be found here:
The annual figures are set out in the graph below:
Although it is impossible to work out how many individual Issuers may have been involved in the STRs, what we can see is that the number of reports has increased exponentially.