Changes to the Listing Rules and DTRs take effect from 6 October 2007 in relation to disclosure of directors' interests

In our 1 August 2007 briefing we promised to keep you informed of developments in relation to directors' disclosures and the potential need to disclose dealings by employee benefit trusts. We can now confirm that the FSA has published revisions to the Listing Rules and Disclosure and Transparency Rules which clarify the position.

Notifications to the market

The amendments to Rule 3.1.4 of the Disclosure and Transparency Rules now make it clear that transactions by PDMRs1 (persons discharging managerial responsibilities) and their connected persons will only need to be notified to the market via an RIS if they are conducted on their own account.

In addition, where a director of a listed company, or a connected person of that director, makes a notification to the company of an interest in its shares pursuant to the information gathering provisions in the Companies Act 20062, that disclosure will need to be notified via an RIS.

Employee benefit trusts

As a result of these changes, the FSA has clarified that dealings in shares by the trustee of an employee benefit trust, which are not on the account of the PDMR but on the account of the general trust fund, continue to be excluded from the notification requirement.