Im not sure how ADRs are set up to begin with. someone with more knowledge in this area might be able to shed some light.
Could this holding from BOA be to kickstart ADR?
from investopedia
To offer ADRs, a U.S. bank will purchase shares on a foreign exchange. The bank will hold the stock as inventory and issue an ADR for domestic trading. ADRs list on either the New York Stock Exchange (NYSE) or the Nasdaq, but they are also sold over-the-counter (OTC).1
Ann: Becoming a substantial holder, page-33
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