FCA’s Market Watch Issue 71 concentrates on changes to advisory firms’ insider lists since the guidance FCA gave in edition 60, when it criticised firms for having unnecessarily large numbers of insiders. It says it has seen significant reductions in numbers of permanent insiders and also enhanced monitoring of access to inside information. FCA notes that even at the largest firms, the typical number of permanent insiders is now 250, when it used to be 450, and the trend continues downwards.
FCA also notes the various measures firms have been taking to reduce the ability of staff to access inside information, such that only those with a specific business need for it can do so.
Finally, FCA notes the requirement in UK MAR to include certain personal information in insider lists, and says lists it receives when investigating possible market abuse often lack the required information.