In the case of a group, should a legal entity that is a part of this group always report/disclose its position when it reaches a threshold?

In a group constituted only of legal entities performing exclusively management activities, how should calculation and reporting be conducted? Who should report?

Being a global fund manager of funds, I use derivative instruments that may result in net short positions in particular issuers when calculated as described in the DR though the strategies being implemented do not, however, relate to particular issuers but aim at increasing or reducing exposure to markets or sectors. An example of the type of strategies that may be employed is: selling exposure to European bank equity through the EuroStoxx Banks index (SX7E) using futures contracts.

In light of the definition of investment strategy under Article 12(2)(a) of the DR and considering that such strategies are aimed at reducing my exposure to sectors or markets and do not relate to particular issuers, are they subject to short position reporting requirements ?

According to Article 12(4) of the DR, the management entity level report specifically excludes from the calculation the positions of funds and portfolios the management of which is delegated to a third party and includes those of funds and portfolios the management of which has been delegated by a third party. Should the same approach apply to the single legal entity level report when that entity is performing both management activities and non-management activities, even though Article 12(5) of DR does not explicitly refer to Article 12(4) on delegation of management?

How should net short position calculation and reporting be conducted when the same single legal entity performs both management and non-management activities?