The Italian offices of Cleary Gottlieb presented a seminar titled, Delay in the Disclosure of Inside Information: Reflections and Regulatory Developments.
Based on the October 2, 2018 update of the ESMA Q&A on MAR, which concerns “systemic delay” by credit and financial institutions, we discussed, together with our co-rapporteur Annarita Puppato from CONSOB, the regulatory framework under which an issuer shall notify CONSOB of the delayed disclosure of inside information, postponing any relevant explanation to the possible subsequent request by CONSOB. In particular, following a brief general introduction, the discussion focused on criteria adopted by CONSOB to assess whether conditions consenting the aforementioned delay are met, including through case studies and examples.
The seminar was part of the Cleary Corporate Breakfast series and took place at the Rome and Milan offices.