" If ML lends those shares to shorters, it remains the "beneficial owner" so no change in substantial holding."
Loaning out the stock reduces the amount they hold, same as when it's returned it increases the amount they hold, that's why there's borrows and returns in their sub holder announcement. So if they loaned more than 0.051% it would still trigger a ceasing to be sub announcement
We've seen it plenty of times where a big bank goes sub holder on mostly borrowed stock
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