Primary Markets Policy
Financial Services Authority
25 the North Colonnade Canary Wharf
London E14 5HS
19th April 2012
CP12/2 Amendments to the Listing Rules, Prospectus Rules, Disclosure Rules and Transparency Rules
Thank you for giving us the opportunity to take part in the above consultation. I have pleasure in enclosing The Investor Relations Society’s response. The Investor Relations Society’s mission is to promote best practice in investor relations; to support the professional development of its members; to represent their views to regulatory bodies, the investment community and government; and to act as a forum for issuers and the investment community. The Investor Relations Society represents members working for public companies and consultancies to assist them in the development of effective two way communication with the markets and to create a level playing field for all investors. It has over 600 members drawn both from the UK and overseas, including the majority of the FTSE 100 and much of the FTSE 250.
In our response to this consultation we have not answered each question individually as set out in the document preferring instead to give our response on behalf of our members in the overall topic areas, while referencing the specific Listing/Prospectus/Disclosure and Transparency Rules to illustrate. We feel this will give you a better overall impression of how we expect the amendments to affect our members, as issuers of predominantly large market capitalisation and their specialist advisors. There is a lot to agree with throughout CP12/2, with certain specific proposals of particular help to issuers, such as the proposed abolition of the notification requirements for class 3 transactions (LR 10.3).There are other proposals which we do not consider directly in the interests of issuers and we identify these areas and explain in our response below.
One general point we would like to raise initially concerns technical guidance. Technical guidance is useful when issued as and when needed and that whilst consolidation into the Rules is a positive move we do not think it is clear whether new technical guidance will be issued as and when needed. We would like to see Technical Guidance to continue to be issued as and when needed rather than wait for changes to the Rules themselves. Perhaps this is something under consideration and there will be clarification in due course.
The Investor Relations Society
3 Bedford Street
London WC2E 9HD
020 7379 1763
Published: 19 April, 2012