The Market Abuse Regulation and FCA’s Disclosure Guidance and Transparency Rules Sourcebook requires firms to have an Insider List. An Insider List should be a single list that can be subdivided. There are prescribed elements to the Insider List. From time to time the FCA may ask for a copy of the Insider List and will expect to receive it within two days of asking.
This template incorporates the regulators requirements as well as aspects that are best practice, for example recording project names and why an individual ceases to possess inside information.
This insider list template is ready formatted for you to simply start recording information. There are notes in cells to explain how to use the cells consistently and to comply with regulatory requirements with drop downs so that you can run a cut of the list for example if you want to identify event-driven entries or review your permanent insiders. There is guidance on how to adjust those drop downs to tailor to your needs.
The template includes instructions so that if you want to implement a consistent template across multiple areas then everyone operates to the same standards. This enables Compliance to own the template whilst the first line, the business, owns and manages their insider lists. It therefore deliberately avoids using regulatory references and explains key regulatory terminology in a business context.
This template covers:
- Required personal data
- Required business data
- Access to inside information
- Internal controls
- Guidance on amending the drop down menu
This template is fully editable by you with standard MS Office fonts and graphics.
This template should be relatively straightforward for someone outside the UK, and not familiar with the UK or EU regimes, to follow and use.
Insider List Template
This document is in Microsoft Excel (*.xlsx) format