Changes to the FCA’s vetting of circulars took effect on 1 April. The revisions decrease the number of circulars requiring approval. Previously LR13.2 required all circulars to be preapproved by the FCA, unless they fell within limited exceptions. From 1 April only those circulars listed require approval. The circulars requiring approval are:
- Class 1 circulars;
- related party circulars;
- share buyback circulars (if required to include a working capital statement);
- reconstruction or refinancing circulars (if required to include a working capital statement); and
- de-listing or transfer of listing circulars.
Impact – decreasing the number of circulars which require the FCA’s approval will be welcomed. As a result of the changes, the FCA will no longer review and approve a number of circulars including: share buybacks that do not include a working capital statement; schemes of arrangement; ratification circulars and shareholder requisitioned general meetings.