In line with Article 13(2) of the DR, the group shall report, and disclose where relevant, the net short position in a particular issuer when it reaches or exceeds a relevant notification disclosure threshold. Provided that a group is not a legal entity, which legal entity within a group shall submit a notification?

How long should the durable medium under Article 5, 6 and 7 of the ITS (Commission Implementing Regulation EU No 827/2012) be stored as evidence of the existence of the agreement to borrow or other enforceable claim?

Can telephone call registrations be considered as a durable medium for the purpose of evidencing the existence of an agreement to borrow or other enforceable claim under Article 5 of the ITS, or of arrangements, confirmations and instructions under Article 6 and 7 of the ITS (Commission Implementing Regulation EU No 827/2012)?

In case of a short sale and a same time cover through a repo transaction, Article 5 of the ITS requires this being “for the duration of the short sale”. However, in practise, the duration of the short position resulting from that the short sale is unknown and that position is covered by a repo that is rolled at maturity as long as the short position exists. Would such an extension of the repo be possible and cover the requirement of the Regulation?

In the case of a group, both the group and the legal entity within the group acquire positions that exceed the 0.2% threshold simultaneously. Subsequently, only the group’s position falls below the 0.2% threshold. Should the legal entity within the group then report even though it has not crossed up or down another threshold?