Letter from PDMR to PCA—continuing obligations under Article 19 Market Abuse Regulation
Letter from PDMR to PCA—continuing obligations under Article 19 Market Abuse Regulation

The following Corporate guidance note provides comprehensive and up to date legal information covering:

  • Letter from PDMR to PCA—continuing obligations under Article 19 Market Abuse Regulation
  • Appendix
  • PCA Notification Form

[On headed notepaper of PDMR]

Strictly private and confidential

To: [insert name of person closely associated with the PDMR]

[insert address of person closely associated with PDMR]

Date: [insert date]

Dear [insert name of PCA],

Notification of transaction in the shares or other debt or financial instruments of [full name of company] (the Company)

In connection with your obligation under Article 19(1) of the Market Abuse Regulation, you are required, as a PCA, to notify the Company and the Financial Conduct Authority (FCA) in writing of every transaction conducted on your own account relating to shares (or debt instruments) of the Company (or in derivatives or other financial instruments relating to those shares, eg options or debt instruments) above the amount of €5,000 per calendar year.

Where you have provided an instruction, consented to or you have otherwise had any control over the transaction, the transaction will be considered as an ‘on own account transaction’, and, under Article 19 of the Market Abuse Regulation, a transaction will be notifiable where, (amongst others) it involves an acquisition or disposal of the Company’s shares, an acceptance of an award of the Company’s shares, an acceptance or receipt of an option or gift from the Company or a third party and the exercise of an option by a PDMR, and the placing of a spread