12 October 2011

欧州発行体連盟が市場濫用規則についてコメント

EuropeanIssuers have noted media reports on possible EU legislative proposals on Market Abuse and are concerned that some of them might be harmful to companies:

1. EuropeanIssuers do not think that it is appropriate to extend the disclosure obligation to issuers traded on demand only on MTFs (or exchange regulated markets).
2. EuropeanIssuers think that a simplification or exemption of the rules on insider lists should apply to all SMEs (small and medium issuers), wherever traded (regulated markets or MTFs).
3. EuropeanIssuers would support a higher threshold for the communication of managers’ transactions. However, every time the threshold is reached, the calculation of the threshold should restart from zero.
4. The communication of managers’ transactions should not be shortened from five working days.
5. A rule allowing an Authority to delay public disclosure only when the information is of systemic importance and in the public interest is not appropriate.
6. There should be an exemption for transactions of a portfolio manager performed in the interest of an issuer’s director.

Full comment letter

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