Short Reporting28 Oct 2019 16:34
Just in case any of you are interested, I had asked the FCA why some changes in short positions are only reported two days after the change rather than the one day I expected. To my surprise they actually replied and gave a clear reason.
In response to your questions we can explain as follows. Article 9 of the SSR requires a person who has a net short position of over 0.20% in the issued share capital of an issuer to notify to the FCA of that position no later than 3:30 pm on the trading day following the day on which the position was reached. Only net short positions over 0.5% are included in our public spreadsheet while those below 0.5% remain private and are not disclosed. Article 9 also requires that, once a net short position is reported to us the FCA must authenticate the source of any notification prior to the publication. Therefore, we have to verify the information received such as the identity of the notifier and additional checks on the data itself. This process is not immediate and can take some time. As the public spreadsheet is uploaded on our website at around 3:30 pm each day, on occasion not all of the net short positions disclosed to us on a given day will appear in that day’s publication. Therefore on occasion the publication of certain notifications may be take place more than 24 hours from the date of submission to us.