How should shares pledged as collateral be considered in terms of ownership and how should given collateral be treated for the uncovered short sale prohibition and position reporting?

Should ETFs be included in the definition of shares for the purposes of Article 12 of the Regulation?

Should Global Depository Receipts (GDR) and American Depository Receipts (ADR) be included in the definition of shares for the purposes of article 12 of the Regulation?

Is there a definition of the terms "position holder" and "reporting person", in order to establish for instance if the position holder is the fund, i.e. the legal entity which owns the short position, or the discretionary investment manager who makes the decision to take the short position.

Would the issuance of a Credit Linked Note be subject to the duration adjustment or to the delta adjustment?