RE: Edwards5 Jun 2025 10:18
Scottyboy are you sure? Where is your information from?
I know ChatGPT makes mistakes but this is what it has to say:
In the UK, under the Disclosure Guidance and Transparency Rules (DTR 5), a TR-1 notification must be submitted each time a notifiable threshold is crossed, not just once at the end of the selling process.
Here's how it works in your example:
A warrant holder is given 400 million shares, which equates to 11% of the issued share capital of the company.
They instruct a broker to sell all 400 million shares over 5 days.
When must TR-1 notifications be filed?
Each time the holding crosses a percentage threshold (either up or down), a TR-1 form must be submitted. In this case, itβs a disposal, so the relevant thresholds are:
11%, 10%, 9%, 8%, 7%, 6%, 5%, 4%, 3%, and finally below 3%.
Timing Requirements:
The TR-1 must be notified to the issuer as soon as possible, but no later than T+2 (2 trading days after the date of the transaction which caused the threshold to be crossed).
The issuer must then announce the notification by the end of the trading day following receipt.
Summary:
Yes, multiple TR-1 notifications must be made, one each time a threshold is crossed during the 5-day sell-down period.
The broker/holder can't wait until the entire process is completed.
These rules are strict and non-compliance can attract FCA enforcement actions.
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It's possible there are multiple warrant holders. For example 5 each with 80 million. Then all would be under the 3% threshold at the outset and any selling would not trigger a tr-1