ESMA has published an updated questions and answers document on MAR. New questions cover whether transactions should be aggregated for the purpose of the trigger for the notification obligation for PDMRs and their closely associated persons, how the price of gifts should be calculated for these purposes, and whether shares received as part of a remuneration package should be notified. A further question addresses whether communications to clients containing only factual information, or those which contain no new information or opinions are investment recommendations for MAR purposes. There are also questions on recommendations relating to derivatives.
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