The Italian Securities Commission (CONSOB) has approved two handbooks, “Management of Inside Information” and “Investment Recommendations,” which offer guidelines under Market Abuse Regulation no. 596/2014 (MAR) and delegated acts. These publications have implications for a range of market participants, including companies with listed equity and debt securities on both Italian regulated markets and multilateral trading facilities, as well as financial analysts and financial institutions acting as dealer managers and underwriters. In particular, the long-awaited handbooks clarify issues that certain provisions of MAR had raised while offering guidance on MAR’s full implementation.
The handbook on management of inside information provides guidelines for creating and implementing internal procedures involving inside information. In addition, the handbook imparts recommendations for developing and maintaining the insider register, as well as for complying with MAR’s disclosure requirements.
The handbook on investment recommendations provides guidelines for fairly presenting and disseminating investment recommendations, as well as for disclosing conflicts of interest and circumstances if CONSOB requests the publication of specific investment recommendations.
CONSOB approved the new handbooks following a summer 2017 public consultation in which Latham & Watkins participated.
The full text of both handbooks is available here: