Intricacies of Global Shareholding Disclosures Monitoring and Reporting – Point-in-Time Data, Rules, Thresholds – Across Multiple Jurisdictions

Investment managers and other financial institutions must grapple with many challenges in an effort to comply with global shareholding disclosures monitoring and reporting requirements. The regulatory aim of shareholding disclosure is to increase market transparency of major holdings in public issuers whose shares trade on regulated markets. Regulators governing global shareholding disclosures monitoring and reporting simply want to know when a financial institution’s equity ownership breaches a certain threshold across the following jurisdiction-specific scenarios:

  • Accumulation of a significant shareholding in an issuer/security
  • Investment in a sensitive industry
  • Investment exposure to a company that has become the subject of a takeover bid
  • Engagement in short selling

Global Shareholding Disclosures Monitoring: regulators demand transparency into a positions history for each legal entityWhile the rationale for shareholding disclosures is clear, its real-world application is anything but straightforward.
More than 95 regulatory jurisdictions around the world enforce some form of shareholding disclosure rules. These rules vary widely from one jurisdiction to the next and change frequently. And, as evidenced during the pandemic, global shareholding disclosures monitoring and reporting rules are among the first regulatory changes to occur in times of market volatility. In each jurisdiction where they have holdings, financial institutions must be able to identify:

  • In-scope holdings
  • Beneficial ownership
  • Aggregation levels
  • Thresholds
  • Reporting triggers

Managing thresholds is complicated for all disclosable datasets. Without up-to-the-minute rules incorporated into transparent disclosure calculation processes, firms can breach thresholds astonishingly quickly: some short-selling thresholds now trigger at 0.1 percent. Reporting must take account of detailed rules for how to aggregate and disaggregate the data depending on fund and legal entity structures. On top of this, regulators demand transparency into a position’s history at any point in time for each legal entity with beneficial ownership.

In this edition of the SLE Series, AxiomSL shares practical thoughts that enable firms to holistically consider the challenges and intricacies inherent in managing regulatory global shareholding disclosures monitoring and reporting. AxiomSL helps organizations identify and avoid the pitfalls of global shareholding disclosure compliance by breaking down its many challenges into three coherent buckets.

  • Regulatory challenges and nuances
  • Market data challenges and nuances
  • Data management and operating model challenges

Download the full paper to discover how investment managers can address these challenges and implement an automated global shareholding disclosures monitoring and reporting solution:


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