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For the purpose of the reporting and disclosure of net short position in shares, what should be the approach to rounding a net short position expressed in percentage?

When firms are comparing the correlation between two sovereign issuers (under Article 3(5) of the Regulation and Article 8(5) of the DR) should they do this on an issue per issue basis, or by comparing the yield curve of the two issuers?

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 ?