A FTSE100 Company Secretary writes...
What are other companies doing regarding the Home Member State notification due by 26 February?
Are companies only emailing the form to the FCA to the specified email address or are they also releasing a stock exchange announcement? It appears the obligation is twofold (DTR 6.4.3R for the form and DTR 6.4.2R for the stock exchange announcement) but I haven’t seen many stock exchange announcements, hence my question.
We added a line to the bottom of a scheduled RNS announcement.
I will be issuing an RNS announcement
Yes – sent the obligatory email and put a line at the bottom of a scheduled announcement. Also done the same for companies with debt listings on LSE.
The FCA have advised that only new issuers are required to notify but it is good practice for all issuers to do so
Yes, in addition to completing the form and emailing it to the UKLA, we combined this one-off communication with our December 2015 Total Voting Rights disclosure. This seems to be the way companies are dealing with this amendment to the DTR rules, ie:
Total Voting Rights and Capital and Home State Declaration
For the purposes of DTR 6.4.2R, the Home State of the Company plc is the United Kingdom.
It’s not exactly the most onerous of tasks………..
We also had a similar query but understood that the obligation was two fold and so we emailed the form to the relevant email address and made a stock exchange announcement.
We noticed that quite a few companies had made stock exchange announcements confirming their home member state although it may not appear obvious as many notifications were combined with other material in the RNS,
I have emailed the form but was also advised to add a sentence to a convenient announcement. I therefore added something to a regular voting rights announcement – I didn’t make a separate announcement.
Does DTR 6.4.4 not apply the default position if a Company fails to notify under 6.4.2 ? In other words the default position is the Home state where the primary listing is .
We are tagging a short sentence into the body of our full year results announcement which is due out next week to meet this requirement. Legal advice from Slaughter and May was that we do need to do both, albeit it’s a duplication of information already provided given we emailed the FCA with the required form back in November. I can’t imagine the FCA will be doing much about non-compliance by next week! I would see what other announcement you can add it in to – maybe your next total voting rights?