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Debt programme updates/establishments and the new Prospectus Directive (PD) regime – Update

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Thomas Amanda
Amanda Thomas



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Addie Ugbenne

Senior PSL


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16 July 2019

There continue to be inconsistencies in the approach taken by the competent authorities when interpreting some of the requirements under the new PD regime. 

In addition, and as noted in the previous edition of this note, new comments continue to be raised in the context of live deals meaning that issuers are having to respond to these within tight deadlines.

The requirements in relation to the content of Final Terms and Summaries, and certain disclosure relating to tax and passporting, continue to generate substantial competent authority comments and, as a result, the uncertainty surrounding these requirements looks set to continue. With some competent authorities recently announcing their inability to guarantee that their usual turnaround times will be met, issuers must continue to anticipate, and be prepared for, longer turnaround times and potentially increased costs during the approval process.

Contributed by Amanda Thomas and Addie Ugbene.