Part III Trading, 13 SME Growth Markets

Subject(s):

Enforcement — Investment business — Market abuse — Regulated activities — Supervision

This chapter considers SME growth markets, introduced under MiFID II as an important strategy to improve access to finance for SMEs in Europe. SME growth markets should be more flexible than regulated markets, but the authors submit this will not be the case: the regime for these will consist of strict rules on insider trading and market manipulation which are subject to supervision by NCAs. These rules, and a disclosure regime ensuring the publication of price relevant information, are important to ensure investor confidence. However, the authors argue that it is neither necessary nor recommendable to apply the respective disclosure obligations under the MAR; instead, a system based on current event reports is sufficient in order to tackle information asymmetries on SME growth markets. The authors conclude that the disclosure regime in Europe should be re-assessed with the aim of allowing market operators to experiment with alternative disclosure obligations.