Correct. It's the beneficial owner who has to disclose....but bear in mid the disclosure is made to the company, not the market -the compnay must then report via RNS.
FMs don't have to disclose until 10%, although some still do so at 3%. MMs must disclose and report to the LSE where holdings reach disclosure parameters however these are not reported via RNS (for obvious reasons).
II's are not hiding in the xo broker numbers. They may have smaller sub holdings and not declare, but very unlikely for reasons of cost, risk and reputation.
In researching this article I have had conversations with the UK Listing Authority, the London Stock Exchange (LSE) and the Financial Services Authority (FSA). There are a number of 'corner-cases' and it is important that the rules reflect this. For example, a market-maker with over 3% of shares in an illiquid smallcap does not have to disclose the fact and neither would a nominee stockbroker, such as Selftrade or The Share Centre.
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