RE: GLG TR17 Nov 2022 14:51
Couple of thoughts on this TR-1 issue, if I may:
Trek – just to clarify your OP, when you said “Being a UK holder they have to declare at each 1% integer above 3%”, I suspect that’s just a typo and you meant “Being a UK issuer...” (i.e. DEC) as per the Handbook?
All TR-1s issued by GLG partners, abrdn, BlackRock, AXA and Pelham Capital have all stated or indicated “UK” for the issuer in section 1. (MJ – for GLG they haven’t put an X in the box to indicate Non-UK so it doesn’t apply, easy to overlook that. They seem to be using the new format issued by the FCA and the other companies haven’t updated their forms yet.)
Confusingly, abrdn and BlackRock have sometimes, but not always, just reported “Below 5%” rather than an actual value, while AXA and Pelham Capital have stated an exact % when between 3-5% (Pelham’s TR-1 on 9 May is a good example). There may be some other reason for allowing the ‘above/below 5%’ reporting that BR in particular have used, rather than the exact %, but I can’t figure it out and I’m not convinced it’s correct. BR and GLG do seem to be trading/adjusting around a core >5% on a regular basis so I can’t see that they are going below 3%, and they should state below 3% rather than below 5% if they were.
The Holder generating a TR-1 has to submit a copy to the FCA as well as the issuing company, although I suspect the FCA just file these without review, until there is a query to investigate. It’s really up to the Company Secretary and their Investor Relations team to challenge any incorrect forms if they think there is a problem.
That’s my reading of the situation, but happy to be corrected if I have misunderstood any of the (often confusing) regulations.