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Positions in Scope for Shareholding Disclosure

Overview

Shareholding disclosure rules (both major shareholding and short-selling regimes) generally concern securities that give their holders ownership in the company issuing them.

This means we are mainly concerned with equity instruments and derivatives on equity instruments, which can be exercised to obtain the underlying equities. However, the scope of disclosure has been further expanded to include cash-settled derivatives and certain types of bond issuance.

The relevant instruments have been determined as:

  • Equities, including Depository Receipts, Preferred Equities, and Rights.

  • Convertible Instruments, including Convertible Bonds.

  • Derivatives, including Futures, Options, CFDs, Swaps, CDS, and Warrants.

  • Bonds, Sovereign Bonds for EU Short Selling rules, and Australian Short Selling Rules, some Corporate Bonds can be in scope for 13F.

  • Units, specifically ETFs and Structured Products.

What’s Not Included?

Although in some cases there is ambiguity around what gives you ownership of a company, the following can be ignored as relevant positions and do not fall into scope for any of the shareholding disclosure rules in any jurisdiction:

  • Bonds, including corporate debt and other fixed-income securities that do not have exposure to sovereign debt, with the exception of some corporate bonds for 13F.

  • Swaps linked to interest rates (interest rates are not in scope for Shareholding Disclosure, irrespective of the derivative), commodities, and FX.

  • Money Market Instruments, such as Commercial Paper and Certificates of Deposits.

  • Commercial Property, such as a lovely office looking across Central Park.

  • Commodities futures on commodities, etc.

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