How to document a decision to delay disclosure of inside information?
According to MAR, issuers need to document the decision to delay disclosure of inside information and be able to provide such information to the national competent authority upon request. The purpose is to ensure that all three criteria defined in article 17.4 in MAR have been met. As such, issuers need to produce a detailed record as to why they regarded the criteria to delay a disclosure, at a specific point in time and thereafter, to be fulfilled.
In Logwise, issuers can choose to produce and store the documentation for each insider list using the bespoke documentation guide. To access the guide, click "PROJECTS" on the top bar menu then "Create".
Select "Inside information", "Delayed disclosure", "Documentation guide" and click "NEXT" to be taken through the different steps to ensure you have documented the information required.
You may document the decision elsewhere and continue to the insider list management by selecting "Skip documentation" and click "NEXT". Alternatively, if you want to use custom templates but store the information in Logwise, select "Custom documentation" and click "NEXT".
If using the recommended Documentation guide, fill in the requested information at each stage and click "NEXT". Once completed, you may review the information before creating the insider list. The documentation may be downloaded as single document.
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