On 24 October 2016 CONSOB published a Consultation Paper on the proposals for certain amendments to CONSOB regulations on issuers (n. 11971/1999) and markets (n. 16191/2007), needed in order to implement the Market Abuse Regulation (EU Regulation No. 596/2014 of 16 April 2014, “MAR”) which came into force on 3 July 2016 – replacing the previous market abuse regime (MAD I).

The changes under consultation mainly concern the following topics:

• Ongoing disclosure requirements;
• Rules concerning issuers of financial instruments held to a considerable extent by the public;
• Investment recommendations;
• Shares’ buy-back programs and stabilisation;
• Insider lists and suspicious transactions;
• Managers’ transactions;
• Minimum threshold to trigger the reporting obligations;
• Aggregation of the positions of managers and their related persons.

As clarified in the impact assessment of the proposed rules, CONSOB intervention is essentially aimed at repealing of the actual rules clashing with the new MAR regime.

Responses to the Consultation Paper (available in Italian language only) may be submitted before 25 November 2016.

Should you wish to submit a response to the consultation, we are available to assist you. Please do not hesitate to contact us for any further clarification on the Consultation Paper.

Contacts:

Vito Vittore
Senior Partner

Elena Pagnoni
Of counsel

Luigi Bonifacio
Associate