On 9 December 2021, the FCA published Primary Market Bulletin 37.

In this edition the FCA:

  • Covers the implementation of postponed rules that require issuers to publish their annual financial reports in a structured format.
  • Explains the importance of adequate business continuity procedures for Primary Information Providers (PIPs) and suggest issuers may want to consider having more than one PIP account.
  • Reviews sponsor requirements to identify and manage conflicts of interest, including some feedback on the range of submissions it has received since it published Technical Note 701.3.

The FCA encourages all sponsors to assess the feedback from its review of sponsor requirements and refresh their understanding of the rules and guidance including Technical Note 701.3. The FCA reminds sponsors that the nature of conflicts will depend on a firm’s business model but nevertheless sponsors are urged to keep their conflict obligations at the front of their mind.

For sponsor firms that have not previously contacted the FCA to request guidance on a conflict case, the FCA anticipates it will be a useful exercise for the firm to reflect on why this has been the case and identify if there are specific areas not previously considered that may be relevant in the future.

The FCA reminds sponsors to contact it at the earliest opportunity and ensure their submission precisely identifies the actual or potential conflict and, where applicable, includes an assessment under the reasonable market user test.