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Practices

Proposed minor changes to DTR

15 March 2010

The FSA has recently consulted on some minor changes to the Disclosure and Transparency Rules (“DTRs”). Their proposals include:

Amendment to DTR 5.3: Disclosure of shareholding during a rights issue

The amendment would exempt investors who passively receive nil-paid rights during a rights issue from aggregating them with other holdings they may have for the purpose of determining whether an announcement may be required under DTR 5 in respect of a change in their holdings.  The proposed exemption would not be available for any nil-paid rights received which the investor trades (or any other disclosable interests) during the rights offer period. The FSA’s concern is to ensure that those shareholders who had no wish to alter their economic exposure to the issuer would, but for this amendment, be under an obligation to disclose a change of holding when they received nil-paid rights.

Amendment to DTR 5.6: disclosure by issuers of total voting rights

This amendment would require issuers to make an immediate announcement of any significant change in total voting rights (“TVR”) of the number of shares in issue share that it has admitted to trading on a regulated market (e.g. the London Stock Exchange Official List) or a prescribed market (e.g. the AIM Market) at any time during a month in which it changes significantly (e.g. due to the completion of a rights issue). The FSA proposes that issuers be obliged to announce a new TVR at the point the change occurs if the new figure represents a dilution of 10% or more.

Amendment to DTR 4.4.8: audit of third country issuers

The FSA intends to clarify the exemptions currently afforded under DTR 4.4.8 to issuers whose registered office is in a non-EEA state and whose laws are considered by the FSA to be equivalent to UK laws. At present, DTR 4.4.8R exempts such overseas issuers from the need to publish annual, half-yearly and interim management accounts in accordance with DTRs 4.1, 4.2 and 4.3. However, the FSA wishes to clarify that this exemption does not extend to the provisions of DTR 4.1.7R(4), meaning that such issuers still need to comply with the rules on preparing audited accounts and the need for their auditors to appear on the relevant register of overseas auditors.

Amendment to DTR 4.4.3R: exemptions for debt issuers

In addition, the FSA also wishes to clarify that the provisions in DTR 4.1.7R(4) do not apply to an issuer which has only debt securities admitted to trading the denomination per unit of which is at least €50,000.

The FSA is expected to report back on the results of its consultation shortly, which closed on 6 March 2010.

For further information, please contact Anthony Brockbank or Dominic Gurney-Champion.